Business ventures, whether JVs, partnerships, franchises, team agreements, strategic alliances or one of the myriad types of business relationships a U.S. company can form outside
Three enforcement actions made clear that there were no distinctions between agents and distributors. They were the Smith & Nephew, Inc., Oracle (2012 and 2022),
Polycom came to FCPA grief in China, as have many other US companies. The bribery scheme was long running, occurring from 2006-2014. They included the
Most franchisors have thorough financial vetting requirements before allowing any person or business to become a franchisee. However, how many of these same businesses perform
There remains a question about franchisor liability under the FCPA. Franchising has been a successful model in the U.S. and now many corporations are looking
Many compliance practitioners generally view distributors as a part of their third-party risk management program, with most of their attention on the pre-contract phase of
One area not usually considered around your business ventures is the financial health of JV partner, teaming partner, strategic partner or any other type of
One area not often considered by the CCO as a key part of any compliance regime is the Corporate Controller. The Controller generally has the
Do FCPA considerations come into play for customers? How should you think about your obligations under the FCPA for a group not traditionally associated with
I want to emphasize again the risks JVs pose under the FCPA. Mike Volkov has stated, “A joint venture requires the integration of disparate company cultures.
