In this article, Nate Lankford discusses third-party corruption and fraud risks and effective compliance strategies. Discussing what we can learn from new enforcement actions, Lankford said, "Recent FCPA cases show that the types of third parties involved in corruption schemes, and their role in improper payments, vary greatly depending on the unique set of pressure points faced by companies in particular industries and locations. In short, recent cases teach us the lesson that you can't predict your third party risks without doing some homework."
Regarding the types of third parties that pose the greatest risk, Lankford said: "To quote Romeo and Juliet, 'What's in a name?' We could ask the same question about 'sales agents' or other third parties -- by any other name, they'd present as much corruption risk. This is to say that it's best to focus on the substance of the third party relationship -- what the third party is actually doing -- not labels."