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
For compliance professionals and the programs they run, politically exposed persons are a big deal. PEPs trigger money laundering and corruption concerns and therefore attract enhanced due diligence. So, I always assumed PEPs are easy to identify.…