Or NE Examples of Improper apter Travel and Entertainment The FCPA: * a $12,000 birthday trip for a government decision- Anti-Bribery Provisions maker from Mexico that included visits to wineries and dinners ' Gl 0,090 spent emditiness. dltinks, ang company also failed to implement appropriate internal con- entertainment for a government official trols to monitor the provision of travel and other things of * queso orean swish gem included $1,000 in “pocket money” for each Companies also may violate the FCPA if they give official payments or gifts to third parties, like an official’s family " a trip to Paris for a government official and his wife members, as an indirect way of corruptly influencing a for- that consisted primarily of touring activities via a eign official. For example, one defendant paid personal bills chauitauadiven vehicle and provided airline tickets to a cousin and close friend of ———_—_—_—_—_—_—_—__—_ the foreign official whose influence the defendant sought in obtaining contracts.'© The defendant was convicted at trial and received a prison sentence.’ the company’s facilities, in reality, no training occurred on As part of an effective compliance program, a com- many of these trips and the company had no facilities at those pany should have clear and easily accessible guidelines locations. Approximately $670,000 of the $7 million was and processes in place for gift-giving by the company’s falsely recorded as “training” expenses.” directors, officers, employees, and agents. Though not Likewise, a New Jersey-based telecommunications necessarily appropriate for every business, many larger company spent millions of dollars on approximately 315 companies have automated gift-giving clearance pro- trips for Chinese government officials, ostensibly to inspect cesses and have set clear monetary thresholds for gifts factories and train the officials in using the company’s along with annual limitations, with limited exceptions equipment.” In reality, durin