Foreign Corrupt Practices Act (FCPA)
The Foreign Corrupt Practices Act (FCPA) is a federal law, enforced by the US Department of Justice, which prohibits payments, gifts, or even offers of “anything of value” to a “foreign official” for the purpose of influencing the official or otherwise “securing any improper advantage” in obtaining, retaining or directing business. It's important to remember that foreign regulations can be complex and constantly changing. Those traveling abroad for university-sponsored business should familiarize themselves with US and international regulations before conducting research or work in another country.
Recommendations for Avoiding Corruption
Princeton faculty, staff and students must be aware that anti-corruption laws apply to universities and stiff penalties are possible, both against you, personally, and against Princeton. The Office of the General Counsel created these FAQs to aid Princeton travelers preparing to conduct work abroad. For questions, please contact the Office of the General Counsel at 609-258-2500.
Be Aware of Local Customs and Regulations
Many other countries have their own anti-corruption or anti-bribery laws. Some countries may have stricter rules than the US, which is a significant reason to be aware of local customs and regulations.
Learn About Corruption at Your Destination
Check out Transparency International’s Corruption Perceptions Index to see where your destination falls on the ranking of countries from the least to the most perceived corruption.
Know the Princeton Policies
Before engaging in purchasing or payment activity, understand Office of Finance and Treasury’s:
- Business Expense Policy - Describes the criteria that all University business expenses must meet in order to be paid by the University and provides examples of allowable and unallowable travel-related expenditures.
- Reimbursement Policy - Addresses deadlines for the submission of reimbursement requests, criteria for reimbursement, and other important reimbursement-related details.
- Travel Policy - Sets parameters for University travel arrangements, information regarding cash advances, etc.
- University Credit Card Policy - Identifies purchases that are not permitted on University credit cards and defines the responsibilities of cardholders and approvers.
- Other related Office of Finance and Treasury policies.
Remember That Perception Matters
Steer clear of any payment that may be perceived as giving you an advantage over others or otherwise could be construed as a bribe.
Exercise Good Judgment
If you encounter any of the following red flags, discuss further with the Office of the General Counsel:
- Foreign official strongly recommending a particular third party
- Unusual payment method (e.g., fees that must be paid in cash, high commissions)
- Secrecy (no transparency in invoices)
- Lack of qualifications by the third party to perform the services
Keep Excellent Records
Maintain accurate financial records of international transactions, including receipts and invoices.
Do Your Homework - Vet Third Parties
Conduct thorough due diligence on third parties who are acting on behalf of Princeton. See General Principles – Purchasing Goods & Services Policy for more on how the Purchasing Department can help in doing one’s homework and vetting prospective third parties.
Get Answers to Your Questions On:
- Export Controls - Contact the Office of Research and Project Administration at 609-258-3090
- Purchasing and Payments - Contact the Financial Services Center at 609-258-3080 or firstname.lastname@example.org
- Risk Management and Insurance - Contact Risk Management at 609-258-3046
- General questions - Contact the Office of the General Counsel at 609-258-2500 or the Office of the Vice Provost for International Affairs and Operations at 609-258-2560