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.
Entries in Intermediaries (42)
There is a long-standing debate over the benefits and drawbacks of using intermediaries to generate and retain business.
What is it about agents, fixers, and intermediaries that makes them so attractive while potentially toxic to multinationals?
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.
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.
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.
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?”
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.