or directly at its domestic and foreign offices. 25
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as well as foreign bribery. As of November 1
as an indirect way of corruptly influencing a foreign
such as Foreign Country. Company A’s stock is listed on a national U.S. stock
the FCPA was not designed to prohibit all forms of hospitality to foreign officials. While the cost here may
and employees of the Electricity Commission are subject to Foreign Country’s
” “foreign political party or official thereof
Company A engages in extensive due diligence of Foreign Company
and its third-party and distributor agreements; (2) performing a risk-based analysis of Foreign Company’s customer
and any other corruption-related issues that have surfaced at Foreign Company over the past ten years.
whether Foreign Company’s employees have been adequately trained regarding those policies
Company A learns that Foreign Company has made several potentially
and its review of Foreign Company’s data
Company A’s ability to conduct pre-acquisition due diligence on Foreign Company is limited. In the
Company A determines that Foreign Company is doing business in high-risk countries