What is satisfactory due diligence under the Foreign Corrupt Practices Act (FCPA)? That question seems to be even more important after the corruption scandal involving Unaoil and the subsequent release of the Panama Papers. Both of these events, however, largely focused on the “who” part of due diligence and the need to know with whom you are doing business going forward. Another important question that doesn’t often come up during due diligence is the “how?”
