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I have a client that is hiring a sales agent in a foreign country.  This agent's territory will likely include contracts subject to FMF rules, sales will be direct commercial.  This particular client compensates all of their sales agents with a commission plan.  I've never worked with FMF before - it appears that commissions are allowed, but they have to be disclosed, they cannot be in violation of Anti-Kickback regulations, and it appears that commissions may need to be split out and paid by the Purchaser's national funds.

My questions:

1. I'd like to wrap my head around this better.  What is the purpose of the FMF rules on commissions/contingent fees?

2. What does the last provision (paid by Purchaser's national funds) mean?

3. Where can I find the source document that discusses FMF commission requirements from a contractor's perspective?

Thanks in advance!


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I have nothing on point to add, except that if the contractor isn't very knowledgeable about commissions and fees associated with international sales --whether or not government-financed or funded--then I would consider that situation to be very very high risk, from a FCPA compliance perspective.

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