Qui Facit Per Alium, Facit Per Se: Best Practices for Third-Party Due Diligence

Intermediaries are a critical part of most business operations, and, as recent DOJ and SEC FCPA enforcement actions – nearly all of which involved intermediaries – demonstrate, they pose significant corruption risk.  In a guest article, Dechert partners Mauricio A. España and Hector Gonzalez detail best practices for mitigating and managing third-party corruption risk before and after an intermediary is hired.  See also the Anti-Corruption Report’s two-part series on representations in third-party contracts, “Nine Clauses to Include (Part One of Two)” (Jun. 25, 2014); “Clauses for High-Risk Situations and Enforcement Strategies (Part Two of Two)” (Jul. 9, 2014).

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