The recent Juniper FCPA enforcement action is a cautionary tale on the corruption risk of giving non-standard discounts to third parties and failing to implement a relevant policy. The Juniper case is not the first time the U.S. government has imposed penalties on a company for failing to analyze and monitor discounts to third parties, but its expectations of companies that engage distributors has changed over the years. In this guest article, Greenberg Traurig shareholders Cuneyt Akay, Sandra Gonzalez and Adelaida Vasquez analyze several enforcement actions involving improper third-party discounts and discuss compliance measures to mitigate that risk. See “Juniper Networks Resolves SEC Charges for $11.7M After Allowing Subsidiary Misconduct to Continue for Years” (Oct. 2, 2019).