Overcoming the Joint Venture “Blind Spot”

Several major FCPA settlements in 2019 involved joint ventures, a fresh reminder that a U.S. issuer can hold a minority interest in a joint venture and still be liable for the joint venture’s misconduct. In a recent Strafford webinar, Hogan Lovells partner Edward Fishman and Miller & Chevalier member James Tillen discussed FCPA risks unique to joint venture relationships. Many companies are “very reluctant to impose any kind of requirements on their joint venture partner,” Fishman said. “That is just a recipe for disaster.” See “Strategies for Mitigating the FCPA Risk of Entering Into Joint Ventures” (May 1, 2013).

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