In this Episode 1 of my special Live from London series, Jonathan Armstrong interviews me on the recent several FCPA enforcement actions where customer were a part of the bribery scheme. I highlight the significance of this emerging development and what it may portend for the compliance practitioner and compliance programs. Some of the highlights include:

  1. How do you perform anti-corruption due diligence on a customer?
  2. Why is managing the contract after it is signed has taken on greater significance?
  3. What is your visibility into the life cycle of customer management as a compliance professional?
  4. What are your internal controls around discounts for customers?
  5. Do you know what is or is not a reasonable discount?

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