FCPAméricas Blog
Archive for Due Diligence category:
How Much Third Party FCPA Due Diligence Is Enough?
7.30.2013
How deep must a company dig when engaging an agent, broker, distributor, supplier, consultant, lawyer, accountant, or other third party? How much third party anti-corruption due diligence is enough? Unfortunately, there is no precise answer to this question. The levels of fair, reasonable, and adequate due diligence are highly context dependent. As a result, FCPA […]
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Transferring Third Party FCPA Due Diligence Responsibility to Your Business Units
7.26.2013
Building third party FCPA due diligence programs can be a daunting task. Reviewing all consultants, agents, distributors, suppliers, and other third parties is often overwhelming for companies with thousands of such relationships. Making sure you have dug deep enough when vetting entities is an uncertain exercise. Getting employees to take seriously the need to consider […]
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Connecting the Dots: Latin America Examples of Common FCPA Anti-Bribery Violations
3.08.2013
FCPAméricas has seen a spike in readership from Latin America suggesting that regional businesspeople and companies are increasingly seeking to understand the FCPA. Since we believe that having relatable examples is useful for new readers and for practitioners tasked with spreading the message to different audiences, this post seeks to ground discussions of common FCPA […]
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More Wisdom from Alexandra Wrage
2.21.2013
Two weeks ago, I was honored to speak at this year’s TRACE Mexico City Workshop. Alexandra Wrage, the Founder and President of TRACE, kicked off the conference by offering some words of wisdom. Alexandra is a recognized authority on FCPA compliance issues. She has given FCPAméricas permission to share some of her thoughts with our […]
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Eli Lilly’s Distributor in Brazil: The Non-Obvious FCPA Risk
12.31.2012
A common misconception about the FCPA is that distributors do not create corruption risk for companies. After all, distributors take title to goods. What they do with those goods is their business, not the producer’s. Eli Lilly’s recent $29.4 million FCPA settlement with the SEC dispels this myth. Actually, enforcement officials have been sending the […]