¶¶Òõ¶ÌÊÓƵ

Facilitation Payment Policy Generator for the USA

Create a bespoke document in minutes,  or upload and review your own.

4.6 / 5
4.8 / 5

Let's create your Facilitation Payment Policy

Thank you! Your submission has been received!
Oops! Something went wrong while submitting the form.

Get your first 2 documents free

Your data doesn't train Genie's AI

You keep IP ownership of your information

Key Requirements PROMPT example:

Facilitation Payment Policy

"Need a Facilitation Payment Policy for our manufacturing company that operates in Southeast Asia, with specific focus on handling customs-related payments and government permits in high-risk territories; must comply with both FCPA and local regulations in Thailand and Vietnam."

Document background

A Facilitation Payment Policy is essential for organizations operating in environments where they may face requests for facilitation payments. This document type is particularly crucial for compliance with U.S. anti-corruption laws, specifically the FCPA. The policy should be implemented when organizations need to establish clear guidelines for handling facilitation payment requests, ensuring proper documentation, and maintaining compliance with legal requirements. It typically includes definitions, procedures, reporting mechanisms, and risk assessment frameworks.

Suggested Sections

1. Purpose and Scope: Defines the policy's objectives and who it applies to within the organization

2. Definitions: Clear definitions of facilitation payments, bribes, public officials, and other key terms used throughout the policy

3. Policy Statement: Company's official position on facilitation payments and prohibited activities

4. Legal Framework: Overview of relevant laws including FCPA, Travel Act, and other applicable legislation

5. Compliance Procedures: Detailed steps to follow when faced with facilitation payment requests

6. Reporting Requirements: Procedures for reporting and documenting facilitation payments or attempts

7. Internal Controls: Description of internal accounting controls and record-keeping requirements

8. Enforcement and Disciplinary Actions: Consequences of policy violations and enforcement procedures

Optional Sections

1. Purpose and Scope: Defines the policy's objectives and who it applies to within the organization

2. Definitions: Clear definitions of facilitation payments, bribes, public officials, and other key terms used throughout the policy

3. Policy Statement: Company's official position on facilitation payments and prohibited activities

4. Legal Framework: Overview of relevant laws including FCPA, Travel Act, and other applicable legislation

5. Compliance Procedures: Detailed steps to follow when faced with facilitation payment requests

6. Reporting Requirements: Procedures for reporting and documenting facilitation payments or attempts

7. Internal Controls: Description of internal accounting controls and record-keeping requirements

8. Enforcement and Disciplinary Actions: Consequences of policy violations and enforcement procedures

Suggested Schedules

1. Schedule A - Reporting Forms: Standard forms and templates for reporting facilitation payment requests or incidents

2. Schedule B - Risk Assessment Matrix: Tool for evaluating facilitation payment risks in different jurisdictions and scenarios

3. Schedule C - Training Materials: Reference materials and guidelines for employee training on facilitation payments

4. Schedule D - Country-Specific Guidelines: Detailed requirements and procedures for high-risk countries where the company operates

5. Schedule E - Approval Matrix: Authorization levels and approval requirements for different types of payments and situations

Authors

Alex Denne

Head of Growth (Open Source Law) @ ¶¶Òõ¶ÌÊÓƵ | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Clauses































Industries

Foreign Corrupt Practices Act (FCPA): The primary U.S. anti-bribery legislation that prohibits companies from making payments to foreign government officials to assist in obtaining or retaining business

Travel Act: Federal law that prohibits travel or use of facilities in interstate commerce to promote unlawful activities, including bribery

Sarbanes-Oxley Act: Legislation requiring public companies to maintain adequate internal controls and accurate financial records, relevant for anti-corruption compliance

Dodd-Frank Act: Contains whistleblower provisions and protections relevant to reporting facilitation payments and other corrupt practices

OECD Anti-Bribery Convention: International convention establishing legally binding standards to criminalize bribery of foreign public officials in international business transactions

UN Convention Against Corruption (UNCAC): International anti-corruption treaty addressing prevention, criminalization, international cooperation, and asset recovery

UK Bribery Act: British legislation with extraterritorial reach that may affect U.S. companies with UK connections, notable for its strict stance on facilitation payments

DOJ/SEC FCPA Resource Guide: Comprehensive guidance document providing insight into FCPA enforcement practices and compliance expectations

DOJ Corporate Enforcement Policy: Policy providing incentives for companies to voluntarily self-disclose FCPA violations and cooperate with investigations

Federal Sentencing Guidelines: Guidelines that outline the components of an effective compliance program and influence penalty calculations

State Anti-Corruption Laws: Various state-specific laws that may contain additional anti-corruption provisions and requirements

Anti-Kickback Statute: Healthcare-specific legislation prohibiting the exchange of anything of value to induce or reward referrals

Internal Controls Requirements: Mandatory procedures and mechanisms to ensure accurate financial recording and prevent unauthorized payments

Record-Keeping Obligations: Requirements for maintaining accurate books and records that properly document all transactions and payments

Whistleblower Protection Provisions: Legal safeguards protecting individuals who report potential violations of anti-corruption laws

Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

Find the exact document you need

Corporate Anti Corruption Policy

A U.S.-compliant policy document establishing guidelines and procedures to prevent corruption and ensure FCPA compliance within an organization.

find out more

Policy Anti Bribery

A U.S.-compliant internal policy document establishing rules and procedures to prevent bribery and corruption in business operations, aligned with FCPA requirements.

find out more

Policy Corruption

A U.S.-compliant anti-corruption policy establishing organizational guidelines for preventing and addressing corrupt practices under FCPA and related regulations.

find out more

No Bribery Policy

A U.S.-compliant policy document establishing organizational guidelines to prevent bribery and corruption in business operations.

find out more

Global Anti Corruption Policy

A corporate policy ensuring compliance with U.S. FCPA and global anti-corruption laws through established guidelines and procedures.

find out more

Global Anti Bribery Policy

A corporate anti-bribery policy ensuring global compliance with U.S. FCPA and international anti-corruption laws.

find out more

Company Bribery Policy

An internal policy document establishing anti-bribery guidelines and procedures for U.S. companies, ensuring compliance with FCPA and related regulations.

find out more

Corruption Statement

A U.S.-compliant document outlining an organization's anti-corruption policies and procedures in accordance with federal regulations.

find out more

Fraud And Bribery Policy

An internal policy document establishing guidelines for preventing and addressing fraud and bribery in compliance with U.S. federal and state regulations.

find out more

Company Anti Bribery Policy

A U.S.-compliant internal policy document that establishes guidelines to prevent and address bribery and corruption within an organization.

find out more

Bribery & Corruption Policy

A corporate policy document ensuring compliance with U.S. anti-corruption laws, including FCPA, establishing guidelines to prevent and address bribery and corruption.

find out more

Anti Bribery And Corruption Policy (Construction)

A U.S.-compliant policy document establishing anti-bribery and corruption guidelines for construction companies under federal and state laws.

find out more

Anti Corruption Policy Statement

A U.S.-compliant policy document outlining an organization's stance and procedures against corruption, aligned with FCPA requirements.

find out more

Anti Bribery Compliance Policy

A U.S.-governed corporate policy establishing guidelines and procedures for preventing and addressing bribery and corruption in business operations.

find out more

Anti Corruption Bribery Policy

A U.S.-compliant policy document establishing organizational standards and procedures to prevent corruption and bribery in business operations.

find out more

Anti Corruption Policy For Small Business

A U.S.-compliant policy document that establishes anti-corruption guidelines and procedures for small businesses, ensuring FCPA compliance.

find out more

Anti Bribery Policy Statement

A U.S.-compliant policy document outlining an organization's anti-bribery and corruption prevention measures, aligned with FCPA requirements.

find out more

Zero Tolerance Corruption Policy

A U.S.-compliant policy document establishing an organization's absolute prohibition of corrupt practices and procedures for maintaining ethical business conduct.

find out more

Anti Bribery & Anti Corruption Policy

A U.S.-compliant policy document establishing guidelines to prevent and address bribery and corruption in business operations, aligned with FCPA requirements.

find out more

Anti Bribery And Corruption Policy Bank

A U.S.-compliant anti-bribery and corruption policy framework for banking institutions, aligned with FCPA and federal banking regulations.

find out more

Anti Bribery & Anti Corruption

A U.S.-compliant Anti-Bribery and Anti-Corruption Policy aligned with FCPA requirements and international best practices.

find out more

Anti Fraud And Corruption Policy

A U.S.-compliant policy document establishing organizational framework for preventing and addressing fraud and corruption, aligned with federal and state regulations.

find out more

Anti Bribery And Corruption Policy Statement

A U.S.-compliant policy document establishing guidelines for preventing and addressing corruption and bribery within an organization.

find out more

Policy For Bribery And Corruption

An internal policy document establishing anti-bribery and corruption guidelines for organizations operating under U.S. jurisdiction.

find out more

Anti Bribery Anti Corruption Policy

A compliance document establishing anti-bribery and corruption protocols in accordance with U.S. federal laws, including the FCPA.

find out more

Corruption Policy

An internal policy document ensuring compliance with U.S. anti-corruption laws and establishing guidelines for preventing corrupt practices.

find out more

Anti Bribery Policy For Company

A corporate policy ensuring compliance with U.S. anti-bribery laws, including FCPA, establishing guidelines to prevent and address corruption.

find out more

Bribery And Corruption Policy

An internal policy document outlining anti-bribery and corruption measures, compliant with U.S. federal and state regulations.

find out more

Bribery Policy

A U.S.-compliant internal policy document that establishes rules and procedures to prevent and address bribery and corruption within an organization.

find out more

Anti Bribery & Corruption Policy

A U.S.-compliant policy document outlining an organization's rules and procedures for preventing bribery and corruption in business operations.

find out more

Global Anti Bribery And Corruption Policy

A U.S.-based anti-bribery policy document ensuring global compliance with FCPA and international anti-corruption standards.

find out more

Fraud And Corruption Policy

A U.S.-compliant policy document establishing organizational guidelines for preventing and addressing fraud and corruption.

find out more

Facilitation Payment Policy

A U.S.-compliant policy document governing the handling of facilitation payments under FCPA and related anti-corruption laws.

find out more

Bribery Prevention Policy

A corporate policy document establishing anti-bribery procedures and controls in compliance with U.S. federal and state legislation.

find out more

Anti Fraud Bribery And Corruption Policy

A U.S.-compliant policy document establishing guidelines and procedures to prevent, detect, and respond to fraud, bribery, and corruption within an organization.

find out more

Anti Fraud And Bribery Policy

A U.S.-compliant policy document establishing guidelines and procedures for preventing and addressing fraud and bribery within an organization.

find out more

Anti Fraud And Anti Corruption Policy

A U.S.-compliant policy document establishing guidelines to prevent and address fraud and corruption within an organization.

find out more

Anti Corruption Statement

A formal statement outlining an organization's anti-corruption policies and procedures, compliant with U.S. federal laws including the FCPA.

find out more

Anti Corruption Policy For Companies

A corporate policy document ensuring compliance with U.S. anti-corruption laws, including FCPA, establishing guidelines to prevent and address corrupt practices.

find out more

Anti Bribery And Corruption Statement

A formal statement outlining an organization's anti-corruption policies and procedures, compliant with U.S. federal and state regulations including FCPA.

find out more

Anti Corruption Policy

A U.S.-compliant corporate policy document establishing guidelines and procedures to prevent corruption and ensure FCPA compliance.

find out more

Anti Corruption Compliance Policy

A U.S.-focused corporate policy document establishing guidelines for anti-corruption compliance under FCPA and related regulations.

find out more

Anti Bribery Policy

A compliance document establishing anti-bribery procedures and controls in accordance with U.S. federal and state anti-corruption laws.

find out more

Anti Bribery And Anti Corruption Policy

A policy document establishing guidelines and procedures for preventing bribery and corruption in accordance with U.S. anti-corruption laws, including FCPA.

find out more

Download our whitepaper on the future of AI in Legal

By providing your email address you are consenting to our Privacy Notice.
Thank you for downloading our whitepaper. This should arrive in your inbox shortly. In the meantime, why not jump straight to a section that interests you here: /our-research
Oops! Something went wrong while submitting the form.

³Ò±ð²Ô¾±±ð’s Security Promise

Genie is the safest place to draft. Here’s how we prioritise your privacy and security.

Your documents are private:

We do not train on your data; ³Ò±ð²Ô¾±±ð’s AI improves independently

All data stored on Genie is private to your organisation

Your documents are protected:

Your documents are protected by ultra-secure 256-bit encryption

Our bank-grade security infrastructure undergoes regular external audits

We are ISO27001 certified, so your data is secure

Organizational security

You retain IP ownership of your documents

You have full control over your data and who gets to see it

Innovation in privacy:

Genie partnered with the Computational Privacy Department at Imperial College London

Together, we ran a £1 million research project on privacy and anonymity in legal contracts

Want to know more?

Visit our for more details and real-time security updates.