Corruption Of Foreign Public Officials: Facilitation Payment Exception Repeal Now Effective

Global Affairs Canada has just announced that the repeal of the facilitation payment exception in the Corruption of Foreign Public Officials Act ("CFPOA") is now in effect (as of October 31, 2017). As we previously discussed, the exception was actually removed from the CFPOA in 2013, but the effective date of that change was postponed indefinitely.

What are Facilitation Payments?

At a high level, facilitation payments are typically amounts paid to subordinate foreign public officials to expedite routine, non-discretionary decisions. Examples of the types of acts that could be considered routine in this context include:

• Issuing non-discretionary business permits or licences;