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Recent FCPA Action Highlights Corruption Risks in Customer Relationships

Corporate Compliance Insights

In this article, Daniel Patrick Wendt and Annie Cho discussed critical takeaways from the Department of Justice's (DOJ) recent deferred prosecution agreement (DPA) with Freepoint Commodities and the need for third-party due-diligence programs to include additional scrutiny of customer relationships in some instances. The authors wrote, "While customer relationships themselves are not often directly included in a corporation's due diligence process, organizations may want to consider screening them to better understand the customer's background, business practices and any potential risks they may pose in terms of compliance with anti-corruption laws like the FCPA."