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ARTICLE · 08 NOVEMBER 2017

"Grease Payments" No Longer Allowed Under Canada's Anti-Corruption Legislation

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On October 30, Canada removed the facilitation payments exemption from the Corruption of Foreign Public Officials Act (CFPOA). This change goes into effect October 31.

CanadaCriminal Law
Danica Doucette-Preville
Danica Doucette-Preville
Glen Jennings
Glen Jennings
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On October 30, Canada removed the facilitation payments exemption from the Corruption of Foreign Public Officials Act (CFPOA). This change goes into effect October 31.

If your corporation is subject to the CFPOA, it is imperative that you review your business code of conduct and anti-bribery policy as well as your operational guidelines abroad to ensure that all facilitation payments are eliminated immediately from your company's operations.

Facilitation payments, usually referred to as "grease payments", are generally characterized as disbursements made to foreign government officials to speed up or facilitate routine transactions, such as permits or the release of goods from customs.

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