Today is Valentine’s Day – a day often associated with flowers.
Many discussions regarding bribery are vague (and compliance a challenge) because the “b” word (bribery) can mean different things in different contexts.
Indeed, many Foreign Corrupt Practices Act enforcement actions concern things of value such as jobs and internships, sport tickets, food and beverage, leisure activities, etc. that are normal and legal in most circumstances.
Yet providing such things of value to a specific type of person (an individual the DOJ/SEC deem to be a “foreign official”) may expose a company or individual to the “b” word.
And this includes flowers.