FCPA Risks - How Are Your Investigators Obtaining That Information?

The Foreign Corrupt Practices Act (FCPA) continues to be a priority of enforcement by the DOJ and SEC.  In conjunction with a couple of upcoming speeches I am doing, I wrote an article that explores an area of considerable risk that is too often not considered at all - the risk of investigators paying bribes to gather information in the course of conducting due diligence or other investigations abroad.  The article describes the associated risks and ways that this risk can be mitigated by attorneys and companies engaging investigative agencies/persons to conduct such investigations overseas.

Article available here: Due Diligence Dues Blues

 
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