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Richard L. Cassin Publisher and Editor

Andy Spalding Senior Editor

Jessica Tillipman Senior Editor

Harry Cassin Managing Editor


Elizabeth K. Spahn Editor Emeritus

Cody Worthington Contributing Editor

Julie DiMauro Contributing Editor

Thomas Fox Contributing Editor

Marc Alain Bohn Contributing Editor

Bill Waite Contributing Editor

Shruti J. Shah Contributing Editor

Russell A. Stamets Contributing Editor

Richard Bistrong Contributing Editor 

Eric Carlson Contributing Editor

Bill Steinman Contributing Editor

Aarti Maharaj Contributing Editor


FCPA Blog Daily News

Entries in Intermediaries (47)

Thursday
Oct112018

Dear Intermediaries: Don’t manufacture your own red flags

I see it time and time again -- third parties that would otherwise pass muster under a client’s due diligence process create their own red flags. 

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Friday
May182018

Alexandra Wrage on Panasonic: Bad actors rarely work alone

At every FCPA conference, someone comments that over 90 percent of FCPA matters involve third party intermediaries. It’s an interesting statistic and can be useful if it helps motivate the team to take due diligence seriously and encourages management to fund the program.

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Friday
May112018

Anne Fleur Goedegebuure: What can go wrong (and right) with third-party due diligence?

Working with third parties continues to be the single biggest corruption risk for business. Almost one in two enforcement actions concluded since the OECD Anti-Bribery Convention came into force in 1999 was the result of bribery through sales agents, intermediaries, distributors or brokers.

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Tuesday
Jan232018

Richard Bistrong: My friend, the agent, blackmailed me

This week I'm traveling to the Middle East for the first time in ten years. It’s a welcome return to a region where I spent a lot of time, and where I enjoyed dealing with agents and end users. Those agents were hard working, sophisticated in their knowledge of the market, and overall uniformly polite.

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Thursday
Aug032017

Bill Steinman: Can you trust your offset advisor? 

Satisfying offset obligations is hard. Readers will recall that offsets are financial obligations imposed on defense contractors by foreign government customers as a condition to defense procurements.  

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Thursday
Apr202017

Tom Fox on third parties: A check up from your desktop

When was the last time you did a third-party program check-up? Not a full review of all your third parties but something you can perform on a quarterly, semi-annual or annual basis with desktop tools available to you or your compliance team.

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Monday
Mar202017

U.S. law prohibits contingent fees in government contracts, except to ‘bona fide’ agents

There is a long-standing debate over the benefits and drawbacks of using intermediaries to generate and retain business.

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Thursday
Jan262017

Rolls-Royce Aftermath: Should we all stop using agents?

Writing in The Guardian, the paper’s financial editor Nils Pratley recently summed up £671 million ($800 million) in fines meted out to Rolls-Royce, in the aftermath of the various corruption investigations, as “big, ugly and serious."

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Tuesday
Nov012016

Richard Bistrong: The dangerous charm of agents

What is it about agents, fixers, and intermediaries that makes them so attractive while potentially toxic to multinationals?

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Wednesday
Aug242016

Richard Bistrong: In defense of, ahem, intermediaries

International success now depends on business leaders having "the foreign policy acumen to distinguish what they can and cannot do,” according to John Chipman, the director-general and chief executive of the International Institute for Strategic Studies.

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Thursday
Aug182016

Alison Taylor: Intermediaries are ‘force multipliers’ for prosecutors

A Gabonese national who was allegedly paid $3.5 million for facilitation services in Africa by hedge fund Och-Ziff was arrested this week as part of an FCPA investigation.

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Monday
Jul252016

Frank Brown: A plan for integrating local partners into the global supply chain

Local firms in emerging markets are often highly attractive to multinationals looking for new suppliers and partners. Those local firms, many of them mid-sized, see joining a global value chain as a key step for survival.

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