FCPA Compliance: When a Foreign Official is a Third-Party (Part II of V)
Compliance officers are trained to spot risks. They have an eagle eye and keen sensitivity. In some cases they have to overcome inaccurate designations – my favorite is a “PEP,” a politically exposed person. I sometimes hear the compliance equivalent of an “Oh, no, we can’t do business with him or her – he or she is a PEP.” Of course, we all know that...