Navigating FCPA Risks of Minority-Owned Joint Ventures

By Ben Kimberley and Addison Thompson (November 5, 2021, 4:09 p.m. EDT) – On October 28, Deputy Attorney General Lisa Monaco said the U.S. Department of Justice will further strengthen efforts to tackle corporate crime.[1]

While practitioners will likely focus on Monaco’s comments on topics such as the emphasis on individual responsibility – i.e. a return to the Yates Memo – it is important not to lose sight of the risks. existing ones that are most likely to lead to investigations and enforcement actions.

One area that the US DOJ and the US Securities and Exchange Commission will no doubt continue to focus on is third-party risk under the US Foreign Corrupt Practices Act. These risks are multiple, …

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