Facilitating Payments

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Defined by the U.S. Foreign Corrupt Practices Act (FCPA) of 1977 and clarified in its 1988 amendments, as a payment to a foreign official, political party or party official for “routine governmental action” such as processing papers, issuing permits and other actions of an official to expedite performance of duties of non-discretionary nature.

These are duties which the recipient of the facilitating payment is already bound to perform. The payment is not intended to influence the outcome of the official’s action, only its timing. Facilitation payments are one of the few exceptions from anti-bribery prohibitions of the law.


Global Anti-Bribery Guidance website