Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Facilitation payment definition

What does Facilitation payment mean? A small, unofficial payment to a public official to expedite or secure a routine governmental action (such as issuing a permit, customs clearance or connecting utilities). The phrase is descriptive and widely used in anti-corruption compliance; it is not defined in UK or Irish legislation. In England and Wales, Scotland and Northern Ireland, the Bribery Act 2010 treats facilitation payments as bribes. There is no exemption for customary, grease or low-value payments. Individuals may commit offences under sections 1 or 6 (including bribery of a foreign public official). Commercial organisations may incur liability for failure to prevent bribery under section 7...

US FCPA compliance and enforcement: scope, anti‑bribery, books and records, internal controls, third‑party risks, DOJ/SEC trends, whistleblowing and data analytics—practical guidance for UK practitioners

Published by a LexisNexis Corporate Crime expert

Practice notes

This Practice Note offers an introduction and addresses matters concerning its scope of application. It sets out best practice guidance on helping your clients meet FCPA requirements, including establishing and running an effective anti‑corruption compliance programme within their organisations. The Practice Note also outlines current FCPA enforcement patterns. For organisations operating across borders, it is crucial that they grasp their duties and constraints under the FCPA. As enforcement intensifies and regulators gain unprecedented visibility into the transactions themselves, informing organisations about the FCPA is a highly valuable professional service lawyers can deliver. For further detail on the FCPA, see Practice Notes: Practical steps in a Bribery investigation—UK and US perspectives and The US Foreign Corrupt Practices Act 1977 (FCPA 1977) and Bribery Act 2010 (BA 2010) comparison table, as well as: Best practices in FCPA investigations—checklist.

FCPA—an overview

As companies ambitiously push into new territories in search of growth, they should move carefully, as this can bring fresh challenges. Multinationals, in particular, face an elevated risk that a subsidiary or affiliate, or an employee or agent, may (whether corruptly or unwittingly) engage in conduct that breaches the FCPA...

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Web page updated on 22/05/2026

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