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Distributors under the FCPA

If there was ever a question that distributors were covered under the Foreign Corrupt Practices Act (FCPA), in 2012, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) made it emphatically clear that this class of entities in a company's sales chain would be treated...

Distributors Should Be Analyzed as Any Other Third Party Representative in the Sales Chain

Ed. Note-David Simon is a partner at Foley and Lardner and Bill Athanas is a partner at Waller Lansden Dortch & Davis, LLP. Both have practices which include FCPA compliance. After my recent post on distributors under the FCPA, David and I had a dialogue on how distributors should be reviewed...

Distributors under the FCPA – Post Game Wrap Up

This week we have focused on distributors and how a company might think through ranking the risk, performing due diligence on and, finally, how to manage distributors going forward. This was spurred on by a discussion that David Simon and I had engaged in previously on LinkedIn. In today's post...