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Risk-based due diligence of third-party intermediaries: a scorecard approach

Companies operating internationally often engage numerous – sometimes even thousands – of third parties around the world to help facilitate their business. Alongside the growth of such relationships, the risks posed by them...more

The Danger Of A “Paper” Compliance Program

The FCPA Guidance contains many important compliance reminders which should be incorporated into every anti-corruption compliance program. Perhaps the most important observation included in the FCPA Guidance was the...more

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