Bad actors and other nefarious actors in the corruption space are continually pushing boundaries of how to facilitate their illegal conduct. U.S. businesses responded to earlier corrupt sales agents who would pay bribes in violation of the FCPA with increasing management of the life cycle of third-party relationship. Another area for concern beyond the funding of bribes for corrupt purposes is the laundering of money paid as bribes or appropriated outright from a foreign government. This last issue involves the continuing saga of the 1 MDB scandal involving the Malaysian sovereign wealth fund.
