Making modest payments to supplement poorly paid officials' low salaries in exchange for services performed would be considered a "grease" payment under the FCPA.

Question

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Grease payments, also known as facilitation payments, are allowed under the Foreign Corrupt Practices Act (FCPA) for the purpose of expediting or securing the performance of a routine governmental action by an official, and are not considered bribes. However, they are intended for non-discretionary actions or services that the official is already obligated to perform, rather than to influence decision-making or gain improper advantage.

Making Modest Payments to Supplement Poorly Paid Officials' Low Salaries