Noatum Logistics Completes Acquisition of the Multinational MIQ Logistics. Read more.

Payment of “Anything of Value”

Payment of “Anything of Value” means to offer, attempt, give, pay, promise to pay or give anything of value.


  • Cash, Gift Card
  • “Tips” (e.g., to customs officials or administrators to expedite their work)
  • Entertainment, Meals
  • Payment of utility or phone bills
  • Payment of rent (e.g., car or truck, house, vacation home)
  • Gifts outside the ordinary course of business, or that exceed a nominal value (e.g., Mont Blanc pens, iPhones, etc.)
  • Travel
  • Payments or gifts to friends, families or other relatives of an individual (including offers of employment)
  • Business information
  • Charitable donations

Practice Notes:

  1. MIQ prohibits bribery in all of its forms. Under no circumstance shall an employee or joint venture partner offer, pay or give (or receive) any form of kick-back, bribe, undisclosed commission or offer excessive entertainment to, for or from a government official, employee of any government-owned or controlled enterprise, or any other party to perform his or her duties to the advantage of the Company or to otherwise obtain or retain business or a business advantage.
  2. Enforcement actions have tended to focus on (1) large, extravagant gifts, travel, or corrupt payments, or (2) small payments or gifts over time that represent a “systematic or long-standing course of conduct” (for example, small unlawful expediting payments made regularly over the course of a year may likely be deemed a violation of local law and the FCPA).
  3. There is no minimum threshold amount for corrupt payments or gifts. Please be aware that an amount that might be considered modest and presumably non-corrupt in the some countries might be “a larger and much more significant amount” and possibly a corrupt payment in another country. If in doubt, please contact the MIQ Legal Department.
  4. If meals or entertainment are to be provided, they must be “reasonable”. If gifts are given, it is a best practice to give company promotional (logo) items.