The Role of an Oversight Committee in FCPA Compliance

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We believe that there are four stages a company needs to traverse in it relationship with a Foreign Business Partner. We define them as (1) Business Justification for a Foreign Business Partner; (2) Background and Due Diligence Investigation of the proposed Foreign Business Partner; (3) Evaluation of the Due Diligence and engagement with appropriate contractual terms and conditions; and (4) Management of the Foreign Business Partner after the contract is signed. This article will discuss the concept of a Foreign Business Partner Review and Oversight Committee in Step 4, the management of a Foreign Business Partner.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Thomas Fox, Compliance Evangelist | Attorney Advertising

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