Control of a Set-aside Entity
FCPA Compliance and Ethics Report-Episode 157-Training of Third Parties Under the FCPA
Polsinelli Podcast - An International Trade Issue That May Impact Your Business
Protecting IP Through Employment Law
FCPA Compliance and Ethics Report-Episode 91, Internal Controls for Third Parties Under the FCPA, Part II
FCPA Compliance and Ethics Report-Episode 63-Managing the Third Party Relationship Under the FCPA, Part I
At the end of December, China acknowledged the existence of the coronavirus, and this burgeoning heath crisis is becoming a supply chain problem. China, a major manufacturing hub for materials, products and components being...more
Now in its third month, the coronavirus outbreak that began in Wuhan, China, has claimed over 2,000 lives and brought one of the world’s most dynamic economies to a near standstill. ...more
While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement. OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions. That is quite an increase...more
This past summer, the Third Circuit Court of Appeals issued a seminal opinion in Oberdorf v. Amazon.com, Inc., which held Amazon could be liable as a seller for products sold by third parties on its website. The issue however...more
Companies will often rely on a network of distributors to help sell their products in emerging markets. From a business economics standpoint, engaging a distributor is often more cost efficient than investing in a sales...more
Fresenius Medical came close to earning a declination under the FCPA Corporate Enforcement Policy. Unfortunately, Fresenius’ effort fell short — but it came close. Fresenius Medical operates more than 3700 dialysis clinics...more
All good things must come to an end. So it is in life, and so it is in business. Eventually all business relationships, including manufacturing relationships, will come to an end. Some relationships end with nary more than a...more
Whether you are in the high-tech industry and managing your channel partners (i.e. third-party distribution network), the pharmaceutical and medical device industry managing a complex network of distributors and...more
Believe it or not, life principles can be used in compliance, especially in due diligence. I always tell my kids that life has a way of setting priorities. As you get older, life becomes simpler and your priorities become...more