Immigration is certainly getting a lot of attention these days in the United States, but companies that assign workers around the world know that the United States is not the only country with complex immigration laws and procedures. The crazy quilt of visas and work permits required and the sometimes maddening bureaucracy that goes with the process is enough to frustrate even the most patient among us. While sometimes tempting, the issue is what happens if that frustration leads to payments being made to government officials to accelerate the process. Companies should not assume that small payments to immigration officials could be OK under the FCPA’s so-called facilitation payments exception. The government, however, has in recent years repeatedly rejected such arguments in the customs context.