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When we think of Foreign Corrupt Practice Act (FCPA) enforcement, what comes to mind are the nearly monthly headlines about multi-million dollar criminal settlements resulting from hundreds of thousands or millions of dollars in bribes to foreign officials. But in-house counsel know that the devil is in the details. It’s the less-publicized, less-spectacular questions relating to facilitation payments and expenses for gifts and hospitality that keep in-house counsel at even the most anti-bribery compliant companies scrutinizing their expenditures.