FCPA exceptions
The Foreign Corrupt Practices Act has three main exceptions:
Reasonable and bona-fide expenditures
A payment that is directly related to the demonstration, explanation, or promotion of products or services, or directly related to the performance or execution of a contract, is considered to be a reasonable and bona fide expenditure and therefore not prohibited.
Payments which are lawful under foreign law
If a payment is lawful under the regulations and legislation of the relevant foreign country, it is not prohibited.
Payments for routine government actions
Payments which secure or expedite the performance of a routine governmental action by a political party, party official, or foreign official are not prohibited under the FCPA.