Remediating Corruption Issues Uncovered During Third-Party Audits

Auditing a third party will almost certainly lead to the discovery of anti-corruption red flags. Before embarking on an audit, a company must both understand what red flags it is looking for and have a plan for how to address problems when they are uncovered. Companies and their lawyers can learn from the experiences of others caught in the glare of the anti-corruption spotlight as to what to do – or not do – when a red flag has surfaced. Drawing on advice from anti-corruption audit veterans and lessons from FCPA settlements, this article provides a starting point for creating such a plan. See our three-part series on enforcing audit rights, the next third-party management frontier: “What to Do Before an Audit” (Nov. 9, 2016); “Conducting an Onsite Audit” (Dec. 7, 2016); “Forestalling Problems, Documenting the Audit and Responding Appropriately” (Mar. 1, 2017).

To read the full article

Continue reading your article with an ACR subscription.