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The Achilles Heel of FCPA Compliance: Bribe-Paying Third Parties

Rarely do we hear or read about the names of third-party bribe payers or the names of their companies. Global companies, particularly those who ship products internationally or rely on third-parties in other ways to bring their products and services to market, are heavily reliant on virtual armies of third-party intermediaries to operate internationally. They are a necessary evil who can act on an organization’s behalf, represent them in the marketplace and potentially trigger significant liability under the FCPA, sanctions or anti-money laundering laws.

Join us each week as we take a deep dive into the various forms of fraud across the world and discuss crime families, penny stock boiler rooms, international money launderers, narco-traffickers, oligarchs, dictators, warlords, kleptocrats and more.

Scott Moritz is a leading authority on white-collar crime, anti-corruption, and in the evaluation, design, remediation, implementation, and administration of corporate compliance programs, codes of conduct. He is also considered an authority in the establishment, training, and oversight of the investigative protocols carried out by financial intelligence, corporate security, and internal audit units.
 

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