31 Days to a More Effective Compliance Program - Following the Money Through Distributors

Thomas Fox
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Polycom came to FCPA grief in China, as have many other US companies. The bribery scheme was long running, occurring from 2006-2014. They included the creation of an off-the books accounting and recordation system for corrupt payments made by or on behalf of Polycom China. The money to fund these bribes came through variations of the basic bribery scheme. There would be a discount between the price reported to Polycom and that paid by the buyer. These discounts were not passed on to the end customer, but instead were intended to See more +
Polycom came to FCPA grief in China, as have many other US companies. The bribery scheme was long running, occurring from 2006-2014. They included the creation of an off-the books accounting and recordation system for corrupt payments made by or on behalf of Polycom China. The money to fund these bribes came through variations of the basic bribery scheme. There would be a discount between the price reported to Polycom and that paid by the buyer. These discounts were not passed on to the end customer, but instead were intended to cover the cost of the payments the distributors made to the Chinese government officials. In other words, this discount would form the basis of the pot of money to pay the bribe.

Three Key Takeaways

1. Channel your inner Woodward and Bernstein and follow the money.

2. Simply because some type of compliance oversight is difficult or requires extra effort, it is no excuse not to monitor.

3. Channel you inner Ronnie Reagan as well and ‘trust but verify. 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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