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Interpreting the Bribery Law

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I recently attended a local human resource management workshop. At the workshop they were giving away door prizes and a grand prize of a paid attendance at a national human resource conference. I won the grand prize which included free registration and expenses up to $1500. My bank is not allowing me to accept it. They are saying it violates our ethics policy based on the Bank Bribery Act. I don't see the connection. The local Human Resources Group is not a customer or vendor of my bank. Is my bank accurate in interpreting the Bribery Law. Anyone could have won the prize?

If the rationale is that it violates your bank's ethics policy, then we would have to read that specific policy to form an opinion. As for the Bank Bribery Act, I don't see even a colorable argument that your acceptance would be a violation of the law. The fact that it was a door prize awarded in a random fashion should eliminate any connotation that it was given to you to curry favor. Moreover, the FDIC's guidance indicates: In general, there is no threat of a violation of the statute...if the benefit would be paid for by the insured state nonmember bank as a reasonable business expense if not paid for by another party. Unless you and your fellow employees pay your own expenses at conferences, the prize benefits the bank, not you.

First published on 11/01/10

First published on 11/01/2010

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