Simon Quoted on "Sophisticated Approach" to FCPA Third-Party Distributor Risk-Analysis
13 August 2014
FPCA Compliance and Ethics Blog
The FPCA Compliance and Ethics Blog published a post, “Thinking Through Risk Rankings of Third Parties,” on August 13, 2014, about how to evaluate distributors for third-party risk under the Foreign Corrupt Practices Act (FCPA). The post acknowledged finding “merit in more sophisticated approaches” such as one developed by Partner David Simon, who advocates that a risk analysis should more appropriately be based on the nature of a company’s relationships with their distributors.
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