Alexandra Wrage on Gifts and Facilitation Payments [Podcast]


By Adam Turteltaub

In many parts of the world, the giving and receiving of gifts is a normal business practice.  The challenge is that gift giving can pose significant risk and constitute a violation of the US Foreign Corrupt Practices Act (FCPA) or UK Bribery Act.

There is also great risk in the paying of facilitation payments for routine services.  They may be permissible under the FCPA but not under the Bribery Act.

So, what to do?

Alexandra Wrage, the founder and President of TRACE International advises extreme caution, for one.  Both gift giving and paying facilitation payments are better avoided.

If gifts must be given, she recommends developing simple, clear-cut guidance and to make it available online 24/7 so that employees have the policy direction they need at the time that they need it.  Pre-approved gifts can help make things even simpler and safer.

When it comes to facilitation payments, simpler is better and the simplest rule of all – don’t pay them, period – is likely best.  If the company has been making payments, stopping abruptly may be problematic, she warns.  It can be better to give everyone involved advanced warning to enable a smoother transition.

Listen in to her podcast to learn more about these two risky areas for global operations.


  1. It is better not to provide any gifts or payments as they are inappropriate and can cause individually or corporate damages.

Comments are closed.