Is your ‘business rationale’ for intermediaries fact or fiction?
Richard L. Cassin
July 20, 2022
Compliance professionals have known for decades that intermediaries are involved in nearly all FCPA anti-bribery violations. The DOJ and SEC say plainly that FCPA enforcement actions “demonstrate that third parties, including agents, consultants, and distributors, are commonly used to conceal the payment of bribes to foreign officials in international business transactions.”… Continue Reading
In nearly all FCPA enforcement actions, agents, consultants, suppliers, distributors, and partners — whether real or faux — have a hand in bribery. They make approaches to foreign officials, set up offshore shell companies, generate fake invoices, and move money through accounts they own or control.…