Davis Polk partner Dan Kahn was quoted in Agenda on recent FCPA enforcement trends. Dan said that “most instances of corruption involve third parties, so implementing robust due diligence for high-risk third parties and monitoring the activities of and payments to the third parties are the critical pieces of such a program.”

Dan continued, “A company that sells products to government customers will need to focus on that process. A company that transports goods through customs in higher-risk countries will need to focus compliance efforts around that.”

“FCPA Enforcement Below Average Despite White House Push,” Agenda (August 22, 2022) (subscription required)

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