Challenges in Ensuring Anti-Corruption Compliance by Distributors
The Justice Department’s recent enforcement action against Smith & Nephew underscored an important point – companies can be responsible for FCPA violations committed by distributors of the company’s products. FCPA compliance professionals already knew that the FCPA can apply to distributors. Reams of paper have been used to explain due diligence procedures for third party agents. These same procedures should be applied to distributors and...