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From Baksheesh to BriberyUnderstanding the Global Fight Against Corruption and Graft$
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T. Markus Funk and Andrew S. Boutros

Print publication date: 2019

Print ISBN-13: 9780190232399

Published to Oxford Scholarship Online: May 2019

DOI: 10.1093/oso/9780190232399.001.0001

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Global Developments in, and Evolution of, Third-Party Due Diligence

Global Developments in, and Evolution of, Third-Party Due Diligence

(p.571) 21 Global Developments in, and Evolution of, Third-Party Due Diligence
From Baksheesh to Bribery

Andrew Boutros

Oxford University Press

Third-party due diligence is a critical element in any anti-bribery compliance program. This chapter discusses the risks posed by the use of third-party agents and intermediaries and how those risks can be assessed, documented, and mitigated. It reviews best practices and procedures covering the full span of third-party interaction, from the initial selection through any potential termination. It includes an in-depth presentation of techniques and procedures for internal and external review, in varying intensity to suit the range of possible risk. With an awareness of common pitfalls and an attention to cost concerns, this chapter provides a thorough and practical overview for any company seeking to meet its ethical and legal obligations under transnational anti-bribery law.

Keywords:   due diligence, risk assessment, third-party management, anti-bribery law, FCPA, compliance

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