Q: Can I pay for a foreign official's transportation to visit our company's facilities?
A: Perhaps, but only with prior approval from the company legal department, which will determine whether paying for the official's travel-related expenses is permissible under the FCPA, local law, and company policy.
Q: What if a government official has a relative looking for a job? Can we offer employment?
A: Be careful! This could appear to be an improper attempt to influence the government official. This can only be done if it would be reasonable to do so, would not be in breach of local law, and is not done to obtain anything from the official.
There will also need to be transparent safeguards. For example, there will need to be an open job posting for all qualified candidates, only fully qualified candidates can be considered, and the position must have an independent basis for existing in the first place.