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FCPA Compliance: Third-Party Diligence Post-Unaoil

Minimizing Corruption Risks When Using Foreign Agents, Distributors and Other Intermediaries

Recording of a 90-minute CLE webcast with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Tuesday, June 20, 2017

Recorded event now available

or call 1-800-926-7926

This CLE video webcast will prepare counsel to companies doing business internationally to perform proper due diligence with foreign agents and intermediaries to minimize the risks of Foreign Corrupt Practices Act (FCPA) violations due to third-party misconduct.


FCPA compliance risks may arise from conduct of foreign third parties and their agents. However, many U.S. companies with an international presence (that often engage third parties) take steps to minimize third-party risks or take steps that prove either inadequate or prohibitively expensive to implement.

The ongoing focus on FCPA enforcement by the U.S. DOJ and SEC makes due diligence efforts regarding third-party agents a high priority. Conducting thorough third-party due diligence can mean the difference between value added to the company and problems that lead to an investigation.

Further, the DOJ and SEC consider the level of due diligence when determining whether they go forward when FCPA violations are alleged. Businesses and their counsel must develop effective compliance programs to minimize third-party risks.

Listen as our authoritative panel examines the special risks created by various types of third-party intermediaries and agents, discusses best practices under the FCPA for due diligence with respect to such third-party agents, and outlines strategies for designing due diligence programs when conducting business around the world.



  1. FCPA risks created by third-party agents
    1. Legal framework for third-party liability
    2. Recent enforcement cases involving third-party activity
    3. Unique risks created by different third parties
    4. Common third-party agent red flags
  2. Core elements of third-party due diligence
    1. Background checks
    2. Due diligence investigation/interview
    3. Contract terms
    4. Oversight/audit of books and records
    5. Training
    6. Compliance certificates
  3. Best practices for third-party due diligence
    1. Investigation of agents in M&A context
    2. Risk-based agent review in global business
    3. Common cost effective strategies


The panel will review these and other key issues:

  • What unique FCPA risks are created by different types of third parties?
  • What cost effective strategies can companies employ to reduce FCPA risks posed by third parties?
  • What guidance is provided for businesses by the recently issued DOJ and SEC resource guide?


Fava, Palmina
Palmina M. Fava

Paul Hastings

Ms. Fava conducts internal investigations with respect to the FCPA, international anti-corruption and anti-bribery...  |  Read More

Medrano, Pedro
Pedro A. Medrano
Senior Counsel, Ethics and Compliance
Time Warner

Prior to joining Time Warner, Mr. Medrano served as Senior Counsel at The Bank of New York Mellon, where he was...  |  Read More

Sibery, Richard
Richard A. Sibery, CPA, JD
Partner, Americas Leader, Fraud & Investigations
Ernst & Young

Mr. Sibery’s practice is concentrated in the areas of fraud and forensic accounting, corporate internal...  |  Read More

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