Employee expense reports can be prime vehicles for bribery schemes, and failing to maintain adequate controls over such reports can put a company in serious FCPA jeopardy. Employees can manipulate, and have manipulated, expense reports in order to provide improper benefits to government officials in the form of gifts, hospitality or charitable contributions – or simply to generate pools of cash from which employees can pay bribes. Implementing a risk-based expenditures program, defining appropriate expense limits and training employees can help to limit a company’s risk. Such policies “help to set the framework for employees regarding company expectations for compliance and ethical business practices,” said Tara Giunta, a partner at Paul Hastings. The Anti-Corruption Report is publishing a three-part series to help companies identify and prevent expense-report fraud. The series will provide advice from FCPA experts regarding: spotting expense-report fraud, setting appropriate expense-report policies, monitoring expense reports and addressing anti-corruption issues raised by the monitoring process. This, the first article in the series, will discuss the risks associated with expense reports; provide advice on using travel and entertainment policies to limit expense-report fraud; and provide strategies for utilizing the training process to decrease expense-report fraud. See also “Ten Strategies for Avoiding FCPA Violations When Making Charitable Donations
” (Jul. 11, 2012).