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How suppliers facilitate fraud and corruption

Tom Fox | February 4, 2018

Just as the myth of the rogue employee is simply that, a myth; there is always another side to corruption. In a bribery case there is a bribe payor and a bribe receiver. While the FCPA does not make illegal the receipt of bribery-infused monies, there are other weapons in the Justice Department such as money-laundering, which can lead to the prosecution of bribe receivers. The Man From FCPA considered this less-well-traveled prosecutorial path when reading recent reports about the investigations into Robert Bosch GmbH and its U.S. subsidiary.

For those who may have forgotten, Bosch is the company which designed and manufactured the software used by Volkswagen to create its defeat device; the illegal software created to evade environmental regulations on deisel emissions. As a former software lawyer, I knew it was highly unlikely that VW’s engineers would have the technical capability to modify the correct lines of code to create their illegal result. There is no doubt...

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