Lessons From Airbus on Third-Party Corruption Risk Mitigation

Most recent anti-corruption cases have involved third parties, and Airbus was no different, Nat Edmonds, a partner at Paul Hastings and former DOJ FCPA prosecutor, said at the SCCE’s 10th Annual European Compliance & Ethics Institute. Edmonds, one of Airbus' U.S. counsel in the January 2020 record-breaking settlement. and Frédéric Tardieu, senior legal counsel at Airbus Helicopters, discussed the evolving global anti-corruption enforcement climate, Airbus’ approach to third-party relationships, and the key components of third-party corruption risk management, including risk-based due diligence, contracts and audit rights, training, monitoring, and governance. This article distills their insights. See our three-part series on the Airbus case: “A Milestone in International Anti‑Corruption Cooperation” (Feb. 19, 2020); “Compliance Lessons” (Mar. 4, 2020); and “The Value of Cooperation” (Mar. 18, 2020).

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