Do FCPA considerations come into play for customers? How should you think about your obligations under the FCPA for a group not traditionally associated with FCPA liability or even FCPA risk? These questions and perhaps others are raised by the FCPA investigation into certain transactions in Venezuela by Derwick Associates and a US company ProEnergy Services. ProEnergy Services supplied turbines that Derwick Associates resold to the Venezuelan government and then installed in that country. This investigation demonstrates why See more +

Do FCPA considerations come into play for customers? How should you think about your obligations under the FCPA for a group not traditionally associated with FCPA liability or even FCPA risk? These questions and perhaps others are raised by the FCPA investigation into certain transactions in Venezuela by Derwick Associates and a US company ProEnergy Services. ProEnergy Services supplied turbines that Derwick Associates resold to the Venezuelan government and then installed in that country. This investigation demonstrates why businesses need to be more concerned with not only who they do business with but how their customers might be doing business. In banking and financial services parlance, you now need to ramp up your Know Your Customer (KYC) information to continue throughout a seller-purchaser relationship, in the context of the FCPA.

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