Approved by: President
Issued             -- June 23, 2015
Revised            --
Last Reviewed -- July 22, 2019
Related Policies:
Anti-Bribery Policy; Honoraria Policy; Non-Resident Alien Payments Policy; Travel Policy; Reporting Financial Irregularities Policy
Additional References: Office of General Counsel website - Anti-Bribery; Compliance and Ethics Helpline tel. (855) 350-9396,
Responsible Official: Chief Ethics and Compliance Officer tel. (202) 319-6170


I. Introduction


The U.S. Foreign Corrupt Practices Act (FCPA) prohibits giving, paying, offering, or promising to pay money or Anything of Value to a Foreign Official, either directly or indirectly, to influence an act or decision of the official so as to violate the law, secure an improper advantage, or obtain or retain business. Such acts are considered bribery and are unlawful. The FCPA applies both abroad and in the U.S., and applies to all Foreign Officials at all levels of government.

All faculty and staff members and agents of the University must comply with the FCPA and the requirements and prohibitions set forth in this policy. If at all uncertain about the lawfulness of a payment or gift, seek guidance and approval in advance. Violations of this policy may subject the individual to disciplinary action, up to and including separation from the University, in addition to applicable civil and/or criminal penalties.


II. Definitions


A. Anything of Value can take many forms, such as cash, gifts, tokens, honoraria, loans, contracts, or charitable or political donations. It may also take the form of payment for or provision of travel, lodging or entertainment. There is no minimum threshold value for when an item triggers the FCPA prohibition. While items that are small or modest typically do not violate the law, if they are intended to influence an act or decision of the Foreign Official, providing the items may be unlawful.

B. Foreign Official means:

  1. An officer or employee of a foreign government, or a department, agency or instrumentality thereof;
  2. An officer or employee of a public international organization (e.g. World Bank, International Monetary Fund, World Trade Organization);
  3. A foreign political party;
  4. A candidate for a foreign official position or foreign political party position; or
  5. Under certain circumstances, the family member of a foreign official.


III. Requirements


A. Prohibition on Bribery


Primary responsibility for compliance with the FCPA rests with the individual. Under no circumstances may a faculty or staff member or an agent of the University provide Anything of Value to or on behalf of Foreign Officials in violation of the FCPA and this policy. If at all uncertain about whether an item or payment is lawful, obtain guidance in advance from the Office of General Counsel (tel. 202-319-5142, CUA-OGC@CUA.EDU) or from the Chief Ethics and Compliance Officer (tel. 202-319-6170, CUA-COMPLIANCE@CUA.EDU).


B. Honoraria and Payments to Non-U.S. Persons


In addition to compliance with the FCPA as discussed above, payments of honoraria must comply with the University's Honoraria Policy, and payments to individuals who are not U.S. residents or U.S. citizens must comply with U.S. immigration and tax laws and with the University's Non-Resident Alien Payments Policy. In order to meet the requirements of the foregoing policies, such payment arrangements should be made well in advance of the anticipated payment.


IV. Reporting Instances of Non-Compliance


Violations of this policy should be reported immediately to the Chief Ethics and Compliance Officer (tel. 202-319-6170, CUA-COMPLIANCE@CUA.EDU) or to the Office of General Counsel (tel. 202-319-5142). Individuals who are uncomfortable using these normal reporting channels should report their concerns anonymously through the University's toll-free Compliance and Ethics Helpline at tel. (855) 350-9396 or online at The foregoing officials will review all reports and determine appropriate actions.