Want to know one of the surest ways to strengthen your organization's anti-corruption capabilities? Start by discovering what you do not understand about the third-parties who help you do business abroad.
The prevailing Foreign Corrupt Practices Act and U.K. Bribery Act storylines focus on intensifying enforcement activity, but fail to drive home the fact that third-party agents—suppliers, joint venture partners, service providers, facilitators, and others are the main characters in the story.
As a recent Bloomberg Law Report indicates; 10 of the 11 corporate FCPA investigations initiated during the first 11 months of 2009 involved payments made by third parties. Not ...