Bill Steinman: Can you trust your offset advisor?

Satisfying offset obligations is hard. Readers will recall that offsets are financial obligations imposed on defense contractors by foreign government customers as a condition to defense procurements.  

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Tom Fox on third parties: A check up from your desktop

When was the last time you did a third-party program check-up? Not a full review of all your third parties but something you can perform on a quarterly, semi-annual or annual basis with desktop tools available to you or your compliance team.

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U.S. law prohibits contingent fees in government contracts, except to ‘bona fide’ agents

There is a long-standing debate over the benefits and drawbacks of using intermediaries to generate and retain business.

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Rolls-Royce Aftermath: Should we all stop using agents?

Writing in The Guardian, the paper’s financial editor Nils Pratley recently summed up £671 million ($800 million) in fines meted out to Rolls-Royce, in the aftermath of the various corruption investigations, as “big, ugly and serious."

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Richard Bistrong: The dangerous charm of agents

What is it about agents, fixers, and intermediaries that makes them so attractive while potentially toxic to multinationals?

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Richard Bistrong: In defense of, ahem, intermediaries

International success now depends on business leaders having "the foreign policy acumen to distinguish what they can and cannot do,” according to John Chipman, the director-general and chief executive of the International Institute for Strategic Studies.

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Alison Taylor: Intermediaries are ‘force multipliers’ for prosecutors

A Gabonese national who was allegedly paid $3.5 million for facilitation services in Africa by hedge fund Och-Ziff was arrested this week as part of an FCPA investigation.

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Frank Brown: A plan for integrating local partners into the global supply chain

Local firms in emerging markets are often highly attractive to multinationals looking for new suppliers and partners. Those local firms, many of them mid-sized, see joining a global value chain as a key step for survival.

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Bill Steinman: The death knell tolls for hiding beneficial owners

It’s a scenario that FCPA practitioners see all too regularly. A due diligence report regarding an intermediary reveals that it’s organized not in its home jurisdiction, but in Cyprus. Or Guernsey. Or Panama.

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Scott Shaffer: When things go wrong, your due diligence was never enough

The Unaoil scandal has again brought FCPA due diligence to the forefront. Specifically, the question asked of compliance officers is, “How much due diligence is enough?” 

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Alexandra Wrage on Unaoil: The importance -- and limitations -- of due diligence

The Unaoil story first published by The Age and Huffington Post on March 30, and supplemented yesterday with another chapter, has it all. There are code names, huge dollar amounts and intrigue. 

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Alere discloses DOJ subpoena in foreign bribery probe

Alere Inc said in an SEC filing Tuesday that it received a grand jury subpoena from the DOJ for documents relating to its sales practices in Africa, Asia, and Latin America.

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