WHEN IT COMES TO FCPA ENFORCEMENT: THE MESSAGE IS CLEAR.
Intentional. Consistent. Systematic.

Any company doing business with third parties overseas has noted intensified enforcement actions, multi-million dollar fines and damaging headlines. The number of Foreign Corrupt Practices Act violations prosecuted by the Department of Justice and Securities and Exchange Commission has increased nearly 2000% over the past five years.

WITH REGARD TO DUE DILIGENCE, THERE ARE NO ESTABLISHED “BEST PRACTICES.” HOWEVER, THERE ARE INVESTIGATIVE PRINCIPLES AND STANDARDS THAT ADDRESS BOTH THE SPIRIT AND LETTER OF FCPA LAW.

 

Multinational corporations are dedicating additional resources to meet FCPA challenges. But exactly what kind of compliance program will federal authorities deem “reasonable” under the law? Where are expectations set for overall corporate policy, training and vetting?

STEELE, which has been providing due diligence and other business investigation services to multinational corporations globally for more than 20 years, has authored a white paper that delineates and explains the components of a robust and realistic due diligence compliance program.

Do you know your …
• Resellers | Channel Distributors
• Vendors
• Marketing Agents and Consultants
• Trading Agents and Intermediaries
• Sales and Licensing Representatives
• Legal Representatives
• Accountants

fcpadd

Complimentary to:
Legal Counsel,
Procurement, Internal Audit,
Human Resource Professionals,
Ethics and Compliance Departments,
& Corporate Security Executives

This paper includes specific procedural recommendations as well a comprehensive look at the associated legal, financial and business considerations when conducting due diligence on third-party intermediaries.

Table of Contents: 

  • FCPA General Overview

  • Third-Party Due Diligence Compliance

  • Regulatory Standards and Expectations

  • Overseas Partner Risk Assessment/Inventory

  • What Constitutes "Reasonable" Third-Party Vetting?

  • Systematic Investigative Procedures
  • How to Institute a Consistent, Intentional Due Diligence Program


Learn more about STEELE's

Business Investigation, Litigation Support and Compliance Audit Services

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About STEELE
STEELE is a global business advisory and risk management company and longtime provider of investigative, security and consulting services for multinational Fortune 500 companies, as well as small and mid-sized businesses, governmental and nonprofit organizations. With its international roster of top experts from a range of relevant disciplines, Steele sets the industry standard for innovative, professional and highly personalized crisis and risk management throughout the enterprise. Having regional offices in 16 strategic locations around the world and engagements in over 90 countries, STEELE’s solutions respond to the complexity of doing business in today’s fluid, outsourced marketplace. 
 

  

Knowing Your Business
Employee Misconduct

Brand Protection
Due Diligence
Loss Control
Knowing Your Risks
Risk Assessment
Business Preparedness
Program Development
Compliance
Knowing You're Secure
Crisis Response
Event Security
Personal Protection
Workplace Stability

MEDIA CONTACT
Leslie McCarthy

Director

STEELE

Tel: +1 (415) 354-3851

lmccarthy@wwsteele.com

 

Worldwide Office Locations

For more information visit our website: www.steelefoundation.com

 

 © 2009 The Steele Foundation & Subsidiaries