Law360, New York ( December 8, 2014, 10:17 AM EST) -- Many companies face the requirement, or perhaps the opportunity, to incur travel and lodging expenses for foreign officials. More often than not, there are sound business reasons for doing so. However, last month the U.S. Securities and Exchange Commission fined two individuals under the Foreign Corrupt Practices Act for using the guise of a legitimate business trip to provide foreign officials with a three-week "world tour." While the FCPA contains provisions that allow companies (or, more technically, provides an affirmative defense for companies) to incur reasonable and bona fide travel and lodging expenses on behalf of foreign officials, the SEC's action underscores that this can be a high-risk activity. To mitigate these risks, compliance professionals should remember the old Russian proverb, "trust, but verify."...