FCPA Exceptions

There are three exceptions to the Foreign Corrupt Practices Act

Payments for routine government actions

Payments which expedite or secure the performance of a routine governmental action by a foreign official, political party or party official are not prohibited.

Payments which are lawful under foreign law

A payment is not prohibited if it is lawful under the laws and regulations of the relevant foreign country.

Reasonable and bona-fide expenditures

A payment which is a reasonable and bona-fide expenditure and directly related to the promotion, demonstration or explanation of products or services or directly related to the execution or performance of a contract is not prohibited.