Every indexed document

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

and DOJ took action against a subsidiary

and it should think critically about its potential

companies should have in place an efficient

and the SPV’s attorney that the SPV was 100% owned and controlled by the government entity. DOJ

the financial institution (1) provided extensive FCPA training to the senior executive responsible for