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Compliance Question of the Week

Question: Are paid expenses considered a thing of value under the Bank Bribery Act?

ANSWER: 

No. Section (c) specifically states: This section shall not apply to bona fide salary, wages, fees, or other compensation paid, or expenses paid or reimbursed, in the usual course of business.

Note: Although compensation under this section is not considered bribery, other regulations and acts do prohibit compensation depending on circumstances – e.g., RESPA Section 8.

Reference: Bank Bribery Act 18 USC 215(c)

 

 
 

 

 


 

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