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Distributors Corruption Foreign Corrupt Practices Act (FCPA)

NAVEX

What a New SEC Enforcement Sweep Is Really Telling Us

NAVEX on

Attention all compliance officers at large technology companies – have you checked your mail lately? Because you might find a letter from the Securities and Exchange Commission with FCPA risk written all over it....more

The Volkov Law Group

2019 OFAC Sanctions Enforcement Review (Part I of II)

The Volkov Law Group on

While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement.  OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions.  That is quite an increase...more

The Volkov Law Group

Managing High-Risk Distributor Risks (Part I of II)

The Volkov Law Group on

Companies will often rely on a network of distributors to help sell their products in emerging markets.  From a business economics standpoint, engaging a distributor is often more cost efficient than investing in a sales...more

The Volkov Law Group

Fresenius Medical’s Bribery Conduct Precludes Declination (Part II of III)

The Volkov Law Group on

Fresenius Medical came close to earning a declination under the FCPA Corporate Enforcement Policy. Unfortunately, Fresenius’ effort fell short — but it came close. Fresenius Medical operates more than 3700 dialysis clinics...more

McDermott Will & Emery

Distribution in China – Legal Issues Part III. Pre-Contract Matters

McDermott Will & Emery has a strategic alliance with MWE China Law Offices, a separate law firm based in Shanghai. "Distribution in China – Legal Issues” is a four-part series. Part I discussed the business models...more

Thomas Fox - Compliance Evangelist

Analyzing the Risk of Distributors Under the FCPA-the Simon Approach

Ed. Note-we continue our series on the risk analysis and assessment of distributors under the FCPA and management of that risk. Today, David Simon contributes a guest post where he articulates another approach to the risk...more

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