Compliance due diligence in a nutshell

Some of the key considerations to contemplate in the context of anti-corruption due diligence include: (1) Transparency International’s Corruption Perception Index ranking of the country’s corruption risk; (2) any business or family relationship between employees, vendors or consultants to foreign officials; (3) ensuring that all contract provisions are consistent with standards of that particular industry and do not provide an inappropriate benefit to any foreign official; (4) ensuring there is an economic purpose for any transactions; (5) reviewing the reasonableness of and types of payments, as well as determining the recipients of payments; (6) reviewing the amount of business the entity has with the foreign government; and (7) reviewing any potential concerns, including a lack of transparency; referrals to this company from foreign officials; subcontractors without apparent justification for their need; and any reluctance to sign warranties of compliance with FCPA and other related laws.

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