31 Days to a More Effective Compliance Program - Distributor Liability Under the FCPA

Thomas Fox
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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 -

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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.

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