Every indexed document

Company A determines that Foreign Company is doing business in high-risk countries

Company A’s ability to conduct pre-acquisition due diligence on Foreign Company is limited. In the

Company A stops the payments and DOJ and SEC investigate.

an employee in Company A’s international sales office (Sales Employee) learns

it does not translate the compliance policies into the local

and its review of Foreign Company’s data

DOJ and SEC have no jurisdiction over its pre-acquisition

which it communicates to its new employees through required online

Company A discloses the conduct to DOJ and SEC

Company A learns that Foreign Company has made several potentially

and what remedial actions are taken if the policies are violated.

whether Foreign Company’s employees have been adequately trained regarding those policies

and any other corruption-related issues that have surfaced at Foreign Company over the past ten years.

and its third-party and distributor agreements; (2) performing a risk-based analysis of Foreign Company’s customer

Company A engages in extensive due diligence of Foreign Company

000 monetary penalty and also settled with SEC

even though it was not being pursued for FCPA

four executives from the predecessor company

the subsidiary’s violations were disclosed

providing certain assurances by DOJ concerning prospective conduct)