Companies often bribe government officials and decision makers by providing them trips in return for tenders, deals, and commercial advantages. There are many ways companies can bribe government officials to win deals, but trips are one of the most popular. Anyone who becomes aware of an SEC-regulated company engaging in trip bribery – such as providing trips to conferences, congresses, product demonstrations, and factory inspections to foreign officials for business – may be able to obtain a reward under the SEC’s program, which was created under the Dodd-Frank Act.
Watch Out for Product/Solution “Demos” & “Factory Inspection” Trips
Technology and manufacturing companies will often provide foreign government decision makers trips under the guise of demonstrating the product or solution or as a “factory inspection” visit. These companies will also use their partners to provide the trips to the officials and will reimburse the partners for their expenses through discounts and rebates once the deal has been obtained. Anyone who becomes aware of companies and/or their channel partners providing trips to government officials to obtain tenders may be eligible for a large reward.
Watch Out for Conferences & Congresses in Healthcare Sector
Pharmaceutical and medical device companies will often bribe government doctors and hospital administrators by providing them international and local trips. Anyone who becomes aware of an SEC-regulated healthcare company or one of its distributors or agents providing trips or other bribes to government doctors or hospital tender officials may be able to obtain a reward under the SEC’s program.
Watch Out for Side Trips
Foreign officials will often schedule side trips to touristy places as part of the company visit or conference event. As part of their visit, they will sometimes include side trips to places like Disney World, Las Vegas, and New York City. Anyone who becomes aware of such trips may have reward eligible information.
Watch Out for Spouses, Family Members, and Girlfriends
Oftentimes, government officials will want to bring their wives, girlfriends, and children on company-sponsored trips. Anyone who becomes aware of an SEC-regulated company providing a trip to a government official’s wife or family member may have reward eligible information.
Watch Out for Travel Agencies and Refundable Tickets
Companies often use travel agencies to funnel trips and cash to foreign officials. Travel agencies have been known to provide foreign officials refundable tickets, which they can cash-in. Anyone who becomes aware of government officials receiving refundable tickets or cash from travel agencies may have reward eligible information.
Watch Out for “Pocket Money” and Falsified Receipts for Meals/Taxis
Companies also use channel partners and travel agencies to provide cash or “pocket money” to government officials on trips. Often, these payments are provided to officials for souvenirs and touristy activities. Foreign officials also will falsify receipts from taxis and restaurants and use handwritten receipts to obtain “reimbursement” from companies. Anyone who becomes aware of government officials receiving cash or falsifying receipts may have reward eligible information.
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Anyone who has knowledge of an SEC-regulated company (or an affiliate, partner, or subsidiary thereof) providing trips to government officials or employees working at state-owned entities should feel free to contact me for a free confidential case assessment, as this could be very valuable information depending upon the circumstances. For more information and details about how FCPA whistleblowers can obtain rewards under the SEC’s program, please click here.
