Optimizing Third-Party Due Diligence in the Wake of Unaoil

Oil-and-gas intermediary Unaoil’s bribery scandal shows that even conducting extensive due diligence on third parties does not eliminate third-party risk, as evidenced by the several major corporations ensnared in the scheme despite their own substantial due diligence. A recent panel discussion hosted by Strafford examined the scandal and offered practical suggestions for making the most of third-party due diligence in its wake. The seminar was moderated by Jay Holtmeier, a partner at WilmerHale, and featured Palmina M. Fava, a partner at Paul Hastings, Pedro Medrano, senior counsel at Time Warner and Richard Sibery, a partner at EY. This article summarizes their insights. See “A New Era in FCPA Disclosure” (Feb. 1, 2017).

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