Conducting Corruption Compliance Interviews Abroad – Thailand
Foreign Corrupt Practices Act (“FCPA”) investigations typically involve third parties or subsidiaries located outside the US since most FCPA violations arise out of the activities of foreign third parties or foreign subsidiaries. But most guides on how to conduct FCPA investigations and interviews seem to ignore this rather obvious fact. It has not however escaped the attention of the U.S....
Things You Never Want to Hear from Your Lawyer in Thailand
Compliance with the U.S. Foreign Corrupt Practices Act is challenging in some jurisdictions, and there are some things you never want to hear from your lawyer, particularly in high-risk jurisdictions such as Thailand. Here are a few “innocent” statements that have been “repeated” as purported anecdotes, followed by comments on why these statements are dangerous indicia of corruption.
“We...