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Cross-Border Cases
Practice review: anti-bribery risk in overseas expansion
Expanding via a third-party agent, the agent's improper payments can expose the company to liability.
A typical scenario: a company expands through a local agent or consultant who makes improper payments to speed approvals, and the company is pursued under a cross-border anti-corruption framework.
Many anti-corruption laws have extraterritorial reach, and companies may be liable for third-party conduct, especially without diligence and controls.
The lesson: run anti-corruption diligence on third-party agents, contract for compliance duties and audit rights, and build payment review and training.