James Tillen Quoted on Anti-Corruption and Commissions in The FCPA Report

"Rolls Royce Settlement Offers Lessons on How to Pay Commissions Without Corruption"
The FCPA Report
02.15.17
James Tillen commented on Rolls Royce's recent settlement with U.S., U.K., and Brazilian anti-corruption agencies, which illustrates inherent risks of paying commissions to intermediaries. This settlement, along with General Cable's December 2016 settlement, indicate that commission caps are not effective in preventing corruption. "I don't think there is any specific numerical value that always raises a red flag nor do I think there is any one 'reasonable percentage' for a commission. In theory, the commission should correlate to the amount of work required of the third party," he said. "Key ways to proactively curb the use of commission payments to third parties as a conduit for bribes is through conducting proper due diligence on third parties before engaging them, training third parties, including contract terms regarding compliance and monitoring the activities of third parties."

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