and any other corruption-related issues that have surfaced at Foreign Company over the past ten years.
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whether Foreign Company’s employees have been adequately trained regarding those policies
Company A discloses the conduct to DOJ and SEC
and its review of Foreign Company’s data
an employee in Company A’s international sales office (Sales Employee) learns
Company A stops the payments and DOJ and SEC investigate.
whether Company B’s employees have been adequately trained regarding those policies
the more likely it is that DOJ and SEC would prosecute Company B. In certain limited
provided that Company B still exists in a form that would
Company A) will depend on consideration of all the factors in the Principles of Federal Prosecution
even if the foreign company or individual
Company A should carefully vet Consultant and his role in the transaction
Company A may consider conducting due diligence on Consultant
Company A should carefully vet Distributor and Local Partner and their
when a company has pre-existing relationships with distributors and other third parties