FCPA Lessons On 3rd-Party Risks And Cooperation Credit

Law360 (October 24, 2019, 4:07 PM EDT) -- Third-party intermediaries continue to create the greatest corruption risk for U.S. companies under the Foreign Corrupt Practices Act, as reflected in the recent Microsoft Corp. settlement. On July 22, after more than six years of investigation, Microsoft reached a settlement with the U.S. Department of Justice and the U.S. Securities and Exchange Commission.

Under the settlement, Microsoft agreed to pay a combined $25.3 million for violations of the FCPA’s books and records and internal accounting provisions arising out of subsidiary operations, and related misconduct of third-party intermediaries in Hungary, Saudi Arabia, Thailand and Turkey.

In 2017, Deputy Attorney General Rod Rosenstein announced...

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