Five Lessons for Third-Party Distributor Risk Management from Microsoft FCPA Settlement (Part III of III)
The Microsoft FCPA settlement, while not significant in the total penalty of approximately $25 million, provides some important instructions concerning distributor and re-seller risks and mitigation strategies. Here are five important lessons learned: Discount Controls and Customer/End User Pricing: Microsoft agreed to provide significant discounts based on false justifications. Microsoft failed to confirm the justification for the discounts that permitted the bad actors to create...