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Expert Analysis

FCPA Due Diligence: The New Normal

Law360 (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....

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