Every indexed document

and NPAs. The Guidelines provide a very detailed and

particularly when the risks are readily apparent. Nor can Company A or its employees shield themselves from

they approved the transaction despite knowing that their concerns were unanswered or the answers they received

their due diligence was incomplete. When the initial inquiry identified significant

including Principal 1’s former college roommate

who told them that this was the region’s most important contract

assuring her that the proposed transaction structure is reasonable and legitimate.

she requests a meeting with Distributor and Principal 1. At the meeting

Company A requires both finance and compliance

notify the Ministry of Immigration and his own ministry of his proposed involvement in the

when a company has pre-existing relationships with distributors and other third parties

the fact that Distributor has requested an additional discount warrants further inquiry into

Company A should carefully vet Distributor and Local Partner and their

and it would cause less disruption for Local Partner to perform

claims that the standard discount price to Distributor creates insufficient margin for Distributor to cover

Company A retains an often-used local distributor (Distributor) to sell Company A’s

Company A may consider conducting due diligence on Consultant

this type of relationship can be susceptible to

Company A should carefully vet Consultant and his role in the transaction

both for its profitability and to open the door to future projects with the