FCPA Compliance: Auditing and Monitoring Third Parties

Minimizing Liability Risks When Using Sales Agents, Distributors and Other Intermediaries

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

Conducted on Tuesday, April 10, 2018

Recorded event now available

or call 1-800-926-7926
Program Materials

This CLE webinar will prepare counsel to companies doing business internationally to establish and carry out auditing and monitoring of foreign agents and intermediaries to minimize the risks of Foreign Corrupt Practices Act (FCPA) violations due to third-party misconduct.


Many FCPA compliance risks arise out of the activity of third-party sales agents, distributors and other intermediaries. Companies should conduct ongoing reviews of FCPA compliance risks associated with using such third parties to minimize these risks.

The U.S. Department of Justice and the U.S. Securities and Exchange Commission have increased their focus on FCPA enforcement, so periodic auditing and monitoring of compliance by third-party sales agents, distributors and other third-party business partners are more critical than ever before.

Companies and their counsel must develop monitoring plans and conduct third-party audits and compliance reviews to minimize the likelihood of FCPA violations by third parties and maximize the effectiveness of their anti-corruption compliance programs.

Listen as our authoritative panel examines the unique risks created by various types of third-party sales agents and other intermediaries, discusses best practices for FCPA monitoring of the activities of third-party agents, and outlines strategies for designing audit and compliance review programs when conducting business around the world.



  1. FCPA risks created by third-party business partners
    1. Legal framework for third-party liability
    2. Recent enforcement cases involving third-party activity
    3. Unique risks created by different third parties
  2. Planning third-party audit and compliance reviews
    1. Scope of work
    2. Timing considerations
    3. Data collection and analytics
    4. Resource allocation
    5. Communication protocols
    6. Deliverables
  3. Conducting third-party audit and compliance reviews
    1. Interviews and data review
    2. Managing the process
    3. Common challenges
    4. “Red flag” findings
    5. Post-review action items
    6. Remediation options


The panel will review these and other key issues:

  • What are the unique FCPA risks created by different types of third parties?
  • What are the essential steps for effective auditing and monitoring of third parties’ FCPA compliance?
  • What cost-effective strategies can businesses utilize to minimize and mitigate FCPA risks posed by third parties?


Carlson, Brent
Brent C. Carlson


Mr. Carlson helps companies in the areas of mergers & acquisitions, internal investigations, and interim...  |  Read More

Edward J. Fishman
Edward J. Fishman


Mr. Fishman has substantial expertise with the Foreign Corrupt Practices Act (FCPA), export control and other U.S. laws...  |  Read More

Martin, George
George D. Martin

Faegre Baker Daniels

Mr. Martin's practice focuses on international mergers and acquisitions, joint ventures and other strategic...  |  Read More

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