Video: Foreign Corrupt Practices Act

In this lesson, Nick Palazzolo, CPA, walks through the Foreign Corrupt Practices Act and how to spot when a business payment crosses the line into foreign bribery. He builds a simple four-question framework: what was offered, who ultimately receives it, why it was offered, and what business result the company was after. Nick explains that an offer, promise, payment or authorization of anything of value can count, that the rule reaches foreign officials, foreign political parties and candidates, and that routing value through a consultant or agent does not remove the exposure. A permit example with a disguised success fee shows each element in action. He then contrasts the narrow facilitating-payment exception for routine, nondiscretionary government actions with payments that buy discretionary preferential treatment. Nick closes with the CPA connection: the Act's books-and-records and internal accounting control provisions for issuers, and how a hidden payment raises both a bribery issue and an accounting issue.