Three enforcement actions which made clear that there were no distinctions between agents and distributors. They were the Smith & Nephew, Inc., Oracle and Eli Lilly and Company. Each of these enforcement actions had different FCPA violations and they each revealed separate steps which a company should take to both prevent and detect FCPA violations in their company.

Three Key See more +

Three enforcement actions which made clear that there were no distinctions between agents and distributors. They were the Smith & Nephew, Inc., Oracle and Eli Lilly and Company. Each of these enforcement actions had different FCPA violations and they each revealed separate steps which a company should take to both prevent and detect FCPA violations in their company.

Three Key Takeaways

1. Use auditing and monitoring.

2. Distributors will be treated the same as other business ventures.

3. Robust due diligence must be performed. See less -