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.
