FCPA Due Diligence: The New Normal

Law360, New York (December 13, 2010, 12:00 PM EST) -- The increasing number of settled Foreign Corrupt Practices Act actions involving third parties has resulted in heightened scrutiny of such relationships. The greatest exposure for most public companies subject to the FCPA has been historically in the area of “pass-through” payments, where an improper payment is made through a third party, such as a consultant or agent.

Governmental guidance encourages companies subject to the FCPA to “exercise due diligence and to take all necessary precautions to ensure that they have formed a business relationship with reputable...
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