FCPA Liability for Third-Party Conduct: Identifying Pitfalls and Minimizing Risk | Practical Law

https://content.next.westlaw.com/practical-law/document/I14e1c74c803d11e698dc8b09b4f043e0/FCPA-Liability-for-Third-Party-Conduct-Identifying-Pitfalls-and-Minimizing-Risk?viewType=FullText&transitionType=Default&contextData=(sc.Default) A Practice Note examining key issues for government investigations of alleged Foreign Corrupt Practices Act (FCPA) violations involving corrupt payments made by third parties. This Note discusses Department of Justice (DOJ) and Securities and Exchange Commission (SEC) theories of liability for third-party misconduct, identifies certain high-risk third parties, analyzes relevant third-party enforcement actions, describes the challenges in investigating potential third-party misconduct, and details best practices companies can use to assess third-party risk to prevent improper conduct.

FCPA Liability for Third-Party Conduct: Identifying Pitfalls and Minimizing Risk

Practical Law Practice Note w-003-5494 (Approx. 35 pages)

FCPA Liability for Third-Party Conduct: Identifying Pitfalls and Minimizing Risk

by Robert C. Blume and John D.W. Partridge, Gibson, Dunn & Crutcher LLP, with Practical Law Litigation

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Maintained • USA (National/Federal)

A Practice Note examining key issues for government investigations of alleged Foreign Corrupt Practices Act (FCPA) violations involving corrupt payments made by third parties. This Note discusses Department of Justice (DOJ) and Securities and Exchange Commission (SEC) theories of liability for third-party misconduct, identifies certain high-risk third parties, analyzes relevant third-party enforcement actions, describes the challenges in investigating potential third-party misconduct, and details best practices companies can use to assess third-party risk to prevent improper conduct.