So the 'dustmen' won't be getting any wine ?

Ha ha ha. I remember as a kid at Christmas they'd knock on your door practically demanding a "tip"/gift etc. It could get nasty if you refused. But those days are gone (I think), particularly as many of the services are run privately now.

No, that's not draconian. However the UK law is (IMHO), but I don't really want to take us the thread off topic. Of relevance is that if a UK person whilst in Cambodia were to bribe, say, a hotel receptionist in order to get a room upgrade then it is a criminal office in the UK. The definition of a bribe is quite widely drawn and catches what some would regard as normal business entertaining/hospitality. Unlike the US FCPA regime it isn't confined to public officials and there are fewer defences (eg no "facilitation payment" defence).

Well, if I'm staying in a hotel I expect that to be done for me as part of the service included in the room rate. Well, I say "expect". Depends where I am, and I'm rarely in the US!

I assure you that every US private company I've worked for in China, had me sign paperwork pledging to adhere to the provisions of the FCPA and RICO statutes when working on behalf of the company, under penalty of dismissal and throwing my @ss to the Feds for noncompliance.

But to be sure, the pledge doesn't cover any tipping I might want to do in my personal life on vacation. :D In Asia those tipping situations are rare occurrences, not the norm. Exercising self-control and following local traditional custom is usually best. If you want to throw extra money around, pool what would have been all your tips into a lump sum, and donate it to a deserving local charity or Children's Hospital or something. Or take your tip money, buy notebooks and pencils locally (thus helping the local economy), and give them to the headmaster of a struggling rural school, for the kids.

Sure. My wording was unclear. The FCPA addresses bribery of foreign officials (and certain others). As you say it applies to all US persons.

The key difference is that the UKBA applies to all overseas bribery, including private sector bribery. So it is much greater in scope. It also covers bribery outside the business realm. There are fewer defences too (eg there is no "facilitation payment" defence, though I appreciate that that is of dubious value). Up to 10 years too, rather than 5!

Note that even US companies in Cambodia can be caught by the UKBA if they also have a presence in the UK.

I found this comparison which seems pretty accurate:
http://tfoxlaw.wordpress.com/2011/03...d-bribery-act/

The UK Act was hurriedly passed through parliament in the "wash up" to the last election. It is highly aspirational in my view and it remains to be seen how effective the SFO is in enforcement.

Back to TIPPING, Khmer service is usually nonchalant at best. They anticipate nothing and seemingly wouldn't notice if you were on fire. In my futile attempts at behavior modification, should I actually get an attentive server or bartender - I reward them by putting the tip in their hands. Otherwise they split it all up. wj

I have a friend in PNH who likes to tip for all service: coffee, a couple of beers etc. I cringe sometimes when meeting up with him and seeing what he's leaving, which is occassionally closing in on 20%.

Thankfully he knows i don't condone the act and doesn't ask for me to contribute.