The u. S. Foreign corrupt practices act implications for international distributors

Second: Due diligence before transaction

• Second: Due diligence before transaction
• ▪ Who IS this new partner?
• Research dictated by size/experience of new partner, transaction
• ▪ New intermediary understands FCPA or related OECD standard?
• ▪ Does ownership of partner make improper use of connections likely?
• ▪ Prior track record in country, particularly in countries with high corruption levels
• ▪ Resources: banks, embassy reports, financial references, customer references
• ▪ Paid research: private background research

• Achieving Compliance – Due Diligence