Intermediaries are crucial to many businesses, sometimes even mandatory, and are replete with corruption risk – under both the FCPA and the U.K. Bribery Act, they can generate criminal liability for their principals if they bribe to win business. In many jurisdictions, intermediaries are routinely used to enter markets; to identify opportunities; to access and build relationships with decision-makers responsible for awarding contracts, including public officials; to assist with navigating complex local laws, regulations and customs; and to win business. How can a company mitigate the risks these ubiquitous third parties pose? In a guest article, James Maton, a partner in Edwards Wildman Palmer UK LLP’s London office, provides strategies to that end by reference to the requirements of the U.K. Bribery Act, one of the most comprehensive anti-bribery statutes in the world, with broad application to global activities connected to the U.K. It requires companies and partnerships to have adequate procedures intended to prevent bribery in both their private and public sector business activities. Maton’s article considers the key principles that should underpin those procedures, and the steps an organisation can take to reduce the bribery risks posed by intermediaries.
Senior Editor Megan Zwiebel recently appeared on a podcast with Perkins Coie White Collar & Investigations partners Gina LaMonica and Caryn Trombino, who discussed the use of AI in compliance programs, including trends in AI-based compliance, steps companies can take to utilize AI in their compliance programs, and how regulators view the use of data and AI in compliance programs. Listen to the podcast here.
Sign inFree trialForgot password×
Sorry, we do not recognise the username and password combination you have entered.
Please ensure you have typed your email address correctly and remember that passwords are case sensitive.
You are logged into a maximum of three different browsers/devices.
Please log in with one previously used and go to My Account to manage the browsers/devices you are using.
A reset link has been sent to the email address provided.
Please be aware that the time taken for mail to be delivered is dependent upon your Internet Service Provider. It should normally arrive within 5-15 minutes.