As previously
reported, the growth in cross-border transactions has been
significant in 2017 thus far. This, coupled with the growing
importance of anti-corruption and anti-bribery legislation on an
international level, serves as a reminder to companies that laws
surrounding the governance of foreign bribery and corruption are
still evolving.
The Corruption of Foreign Public Officials Act
(CFPOA) is of particular importance to Canadian
businesses, as it applies to all businesses (including
not-for-profit organizations) formed under the laws of Canada or
any of its provinces or territories. In 2013, the Canadian
government amended the CFPOA in an attempt to address criticisms
from international institutions and strengthen its stance against
bribery and corruption. Included in these amendments was the
commitment to phase out the "facilitation payment"
exemption at a date that has yet to be determined.
