Considerable uncertainty can arise when parties co-invest alongside one another in the same entity, leading to an array of potential corruption and compliance risks.  Co-investor relationships can take many forms – from garden-variety joint venture partnerships, to investments with state-owned entities, to sophisticated private equity transactions – each with different risk profiles.  Adding to the complexity, the DOJ and the SEC expect co-investors to self-police for corruption, even while co-investors are often left in the dark about the contours of appropriate compliance and anti-corruption efforts.  In a recent Practising Law Institute event, experts with diverse perspectives from Goldman Sachs, Cerberus Capital, Gibson Dunn, WilmerHale and Ropes & Gray discussed the complications that can occur throughout the lifecycle of co-investor relationships.  This article, the second of two, discusses essential compliance provisions when formalizing the new venture; the challenges of holding a minority stake in a joint venture; and best practices for conducting an investigation if there is a corruption issue.  The first article described important due diligence steps for both the co-investor and the target to take before the transaction.  See also “FCPA Compliance in Non-Controlled Joint Ventures” (May 14, 2014).