In The Review of Securities & Commodities Regulation: FCPA Update: Third-Party Risks and Enforcement Actions

January 10, 2018 - The article, "FCPA Update: Third-Party Risks and Enforcement Actions?" by Michael Huneke and Ashley Hodges, was published in The Review of Securities & Commodities Regulation.

Recent U.S. government guidance and enforcement activity have emphasized the importance of addressing the corruption risks posed by third-party agents or consultants operating overseas. After discussing the FCPA legal framework and government guidance on third-party management, this article addresses the recent cases that provide a reminder of the risks, and exemplify the compliance programs and controls that are needed to mitigate them.

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