FCPA Frequently Asked Questions-Office of the General Counsel - Carnegie Mellon University

FCPA Frequently Asked Questions

CMU is a non-profit educational institution. Isn't the FCPA about for-profit companies?

The FCPA is about bribery. As long as I’m not giving anyone envelopes of cash, aren’t I ok?

The FCPA prohibits payments to foreign government officials. I only interact with foreign professors and university administrators. What do I have to worry about?

The FCPA doesn’t prevent me from exchanging gifts with my foreign colleagues, does it? That would be rude.

I only give gifts, or pay for meals, that are de minimis in value. Isn’t there a dollar threshold for the FCPA?

The University's FCPA Guidance refers to "family members" of foreign officials. Does the FCPA cover family members? How close must a relative be to be considered a family member for purposes of the FCPA?