Microsoft’s recent $25‑million settlement with the SEC and DOJ demonstrates, once again, that partnering with third parties abroad requires careful vetting and well-designed internal controls. While the company was dinged by the SEC for misconduct in four countries, and its Hungarian subsidiary entered into a non-prosecution agreement with the DOJ, its tech-focused remediation efforts helped the company earn cooperation credit despite failing to self-report. We examine how a reliance on channel partners, a lack of oversight on discounts and incentives to close deals quickly landed the tech giant in hot water. See “Channeling the Channel-Partner Risk: Addressing Anti-Corruption Risk with Channel Partners in the Technology Sector” (Jun. 21, 2017).