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©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide
LeveragingYourAnti-
BriberyComplian...
©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide 21/2/2017
1. Introductions
2. Sanct...
3©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide
Introductions
31/2/2017
4©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide
SanctionsOverview
41/2/2017
© 2016 Baker & McKenzie LLP 5
Sanctions Toolbox
Comprehensively
Sanctioned
Territories
Significant
Sanctions
Limited Sanct...
© 2016 Baker & McKenzie LLP 6
U.S. Sanctions Programs
Comprehensive
Anti-circumvention / Facilitation / Causing violations...
© 2016 Baker & McKenzie LLP 7
Prohibitions/Requirements include:
‒ Dealings with Comprehensively Sanctioned Territories an...
© 2016 Baker & McKenzie LLP 8
Prohibited Facilitation
‒ Issuing, advising, confirming, negotiating, etc. letters of credit...
© 2016 Baker & McKenzie LLP 9
FCPA / Sanctions Compliance Intersections
‒ Application
‒ Penalties
‒ Risks
‒ Violations
© 2016 Baker & McKenzie LLP 10
Similar Extraterritorial Reach
‒ Significant Extraterritorial Reach
 The FCPA can apply to...
© 2016 Baker & McKenzie LLP 11
Similar Penalties and Sources of Risk
‒ Significant Financial Penalties and Potential Incar...
© 2016 Baker & McKenzie LLP 12
Convergent Risks in Certain Markets
‒ Markets with higher risk of corruption also tend to h...
© 2016 Baker & McKenzie LLP
FCPA/Sanctions Risks in the Supply Chain
Establishing
Global
Manufacturing
Operations
Design,
...
© 2016 Baker & McKenzie LLP 14
FCPA/Sanctions Risks in the Supply Chain
‒ Under the FCPA, a U.S. company may be liable for...
© 2016 Baker & McKenzie LLP 15
Overlap in Knowledge Standards
‒ FCPA Violations Require that Conduct is “Knowing”;
‒ Crimi...
© 2016 Baker & McKenzie LLP 16
‒ Failure to identify indirect business activities with proscribed
restricted parties
‒ Ove...
17©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide
In-House Perspective
171/2/2017
Russia: From Emerging Market to Persona
Non-Grata
• Sanctions were imposed rapidly and had immediate legal effect
• GD bus...
Russia: From Emerging Market to Persona
Non-Grata
• Export restrictions
• ITAR – denial of licenses, existing TAA/MLAs sub...
Iran and Cuba: Are they Open for
Business?!
• Cuba
– March 15, 2016: CARC and EAR significantly amended
• Expand the Abili...
Key Question #1: Does the transaction involve any parties
located in a sanctioned country?
• Sanctions vary in scope depen...
Key Question #2: Does the transaction involve any
restricted parties?
• OFAC maintains various restricted party lists that...
Lessons Learned
• Critical to act promptly
– “Task force” created, regular meetings internally and calls with outside
coun...
Lessons Learned
• Consistent Interaction with OFAC (via outside counsel)
– Informal guidance
– Filed required blocked prop...
25©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide
ComplianceConvergence
251/2/2017
©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide 261/2/2017
Common Elements of Effec...
©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide 271/2/2017
Leverage ExistingComplia...
©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide 281/2/2017
1. Do business with or p...
©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide 291/2/2017
Recommendations
U.S. Par...
©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide 301/2/2017
Helpful Resources
• OFAC...
©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide 311/2/2017
Helpful Resources
32©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide
Networking Break
321/2/2017
33©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide
CaseStudies
331/2/2017
Case Study # 1
You are the Pumpkinseed North America compliance officer. Your business
development (BD) director has been ...
Case Study # 1, Cont’d…
After clearing red flags, the application is approved and the sales rep is now under
contract. The...
Case Study # 2
Pumpkinseed France, via an independent distributor, is favored to secure a contract
with Stroytransgaz, a R...
Leveraging Efficiencies
Revisiting each of the hypotheticals, consider how you might leverage your resources to
handle bot...
38©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide
Q&A
381/2/2017
Visit us online at
www.TRACEinternational.org
facebook.com/TRACEinternational
linkedin.com/company/
TRACE-international-in...
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Leveraging Your Anti-Bribery Compliance Program to Make Sanctions Compliance Easier (2016 Compliance & Ethics Institute P13)

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–– The evolving sanctions landscape: Current U.S. sanctions
regimes and how to adapt to changes.
–– How existing anti-bribery risk assessment and due
diligence processes can be the foundation for sanctionsfocused
programs.
–– Best practices for training employees on compliance with
sanctions regimes.

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Leveraging Your Anti-Bribery Compliance Program to Make Sanctions Compliance Easier (2016 Compliance & Ethics Institute P13)

  1. 1. ©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide LeveragingYourAnti- BriberyCompliance Program to MakeSanctions ComplianceEasier Ryan Fayhee, Baker & McKenzie LLP Catherine Razzano, General Dynamics Anne-Marie Zell, TRACE SCCE Compliance & Ethics Institute September 25, 2016
  2. 2. ©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide 21/2/2017 1. Introductions 2. Sanctions Overview 3. In-House Perspective 4. Compliance Convergence --- Networking Break --- 5. Case Studies 6. Q&A WorkshopAgenda
  3. 3. 3©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide Introductions 31/2/2017
  4. 4. 4©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide SanctionsOverview 41/2/2017
  5. 5. © 2016 Baker & McKenzie LLP 5 Sanctions Toolbox Comprehensively Sanctioned Territories Significant Sanctions Limited Sanctions Restricted Persons  Crimea, Cuba, Iran, North Korea, Sudan, Syria  Burma/Myanmar, Russia  W. Balkans, Belarus, Burundi, Central African Republic, Côte d’Ivoire, DR Congo, Iraq, Lebanon, Libya, Somalia, South Sudan, Ukraine, Venezuela, Yemen, Zimbabwe  Specially Designated Nationals (“SDNs”)  Terrorists, WMD proliferators, human rights violators, transnational criminal organizations, narcotics traffickers, Magnitsky, rough diamonds, foreign sanctions evaders, etc.
  6. 6. © 2016 Baker & McKenzie LLP 6 U.S. Sanctions Programs Comprehensive Anti-circumvention / Facilitation / Causing violations Individuals / Entities Goods / Technology Services Investment Asset freeze / Blocked property Making available / Dealing Funds transfer Arms / Dual-use Sanctioned country origin Other Finance Insurance Brokering Sectors
  7. 7. © 2016 Baker & McKenzie LLP 7 Prohibitions/Requirements include: ‒ Dealings with Comprehensively Sanctioned Territories and their blocked governments (including state-owned/- controlled entities) ‒ Prohibitions on dealings, transactions, funds transfers, investments, exports, imports, etc. ‒ Prohibition on dealing in goods of sanctioned country origin ‒ Causing, conspiring, aiding or abetting violations by others ‒ Blocking and reporting of property interests of SDNs ‒ Reporting of rejected transfers ‒ Increasing disclosure obligations
  8. 8. © 2016 Baker & McKenzie LLP 8 Prohibited Facilitation ‒ Issuing, advising, confirming, negotiating, etc. letters of credit ‒ Providing/arranging trade financing ‒ Processing/clearing/settling individual transactions ‒ Approvals or directions ‒ Negotiation/drafting/review of commercial terms, contracts ‒ Bank guarantees; warranties ‒ Referral of business to non-U.S. Persons ‒ Certain forms of IT support/access ‒ Strategizing business ‒ Changing policies or procedures to enable transactions ‒ Other support, including legal advice, technical, credit review, etc.  Sanctions compliance advice is permissible and is not prohibited “facilitation”
  9. 9. © 2016 Baker & McKenzie LLP 9 FCPA / Sanctions Compliance Intersections ‒ Application ‒ Penalties ‒ Risks ‒ Violations
  10. 10. © 2016 Baker & McKenzie LLP 10 Similar Extraterritorial Reach ‒ Significant Extraterritorial Reach  The FCPA can apply to:  U.S. persons, businesses, and their third-party agents and foreign subsidiaries even when scheme is devised and executed outside the U.S.  Foreign issuers of securities on a U.S. stock exchange  Foreign persons who engage in interstate commerce or act in furtherance of an improper scheme in the U.S.  Sanctions apply to:  “U.S. Persons”  Entities owned or controlled by U.S. Persons (foreign subsidiaries) for the Cuba and Iran programs
  11. 11. © 2016 Baker & McKenzie LLP 11 Similar Penalties and Sources of Risk ‒ Significant Financial Penalties and Potential Incarceration  FCPA: fines up to $25 million (or twice the gain or loss caused by the violation) and/or 20 years imprisonment per violation  OFAC: fines up to $20 million (or twice value of the transactions) and/or 30 years imprisonment per violation  Collateral designation as SDN or Foreign Sanctions Evader; revocation of export or OFAC licenses; negative publicity; loss of reputation ‒ Similar Risks from Particular Individuals and Third Parties  The same employees tend to be at the highest risk of both FCPA and sanctions violations (e.g. customer-facing sales employees in high risk jurisdictions)  Third parties are outside of core systems controls , can pay bribes on your behalf and sell into sanctioned countries
  12. 12. © 2016 Baker & McKenzie LLP 12 Convergent Risks in Certain Markets ‒ Markets with higher risk of corruption also tend to have higher trade compliance risk  China: Corruption Risk (SOEs as Govt. “Instrumentalities”) + Export Risk (EAR, ITAR, Entity List) + Cyber Sanctions  Russia: Corruption Risk + Sectoral Sanctions + Export Risk (EAR, ITAR, Entity List) + SDNs  Oil and Gas, Energy, Mining, and Defense: Corruption Risk (JVs, 3rd Parties) + Country Sanctions + SDNs
  13. 13. © 2016 Baker & McKenzie LLP FCPA/Sanctions Risks in the Supply Chain Establishing Global Manufacturing Operations Design, Production & Sourcing – Foreign Direct Investments – Greenfield Projects – Cross-Border M&A – Joint Ventures – Restructuring & Integration – Research & Development – Joint Development – IP Licensing – Trade Secret Protection – Patent / Trademark Protection & Enforcement – Product Safety – Outsourcing Arrangements – Supply Agreements – Purchasing Agreements – Contract Manufacturing – Toll Manufacturing Import / Export & Cross-Border Transit Downstream Distribution, Logistics and Sales Advertising, Marketing & Promotions Post-Sales – Customs & Import Duties – WTO/Free Trade Agreements – Export Controls & Trade Sanctions – Antiboycott Controls – Antidumping/ Section 337 Cases – INCOTERMS – VAT/Indirect Taxes – Agency, Reseller, Distribution & Franchise Agreements – Logistics Contracts – Anti- Counterfeiting Protection and Enforcement – Packaging & Product Labeling – Advertising Agreements – Data Privacy – Consumer Protection – Product Recall/ Liability – Intellectual Property Litigation – Warranty/ Repair – Maintenance & Support – Recycling & Disposal – Waste Management Commercial, Compliance & Risk Management – Tax Compliance – Third Party Due Diligence – Third Party Compliance Training – Environmental Compliance – Competition Law Compliance – Labor & Employment Practices – Regulatory Approval & Public Procurement – Foreign Direct Investment Compliance – Industry Specific Standards – FCPA / Anticorruption – CSR Policies Structuring & Strategy Structuring & Strategy – Planning – Structuring – Country Selection – Investment Opportunity
  14. 14. © 2016 Baker & McKenzie LLP 14 FCPA/Sanctions Risks in the Supply Chain ‒ Under the FCPA, a U.S. company may be liable for improper payments made by a foreign third party on the company’s behalf even if the company had no actual knowledge of such payments ‒ Under OFAC regulations, a U.S. company may be liable for transactions violating trade sanctions undertaken by a foreign third party when that conduct is directed, approved, or facilitated by U.S. persons
  15. 15. © 2016 Baker & McKenzie LLP 15 Overlap in Knowledge Standards ‒ FCPA Violations Require that Conduct is “Knowing”; ‒ Criminal Sanctions Violations require “Willful Conduct”:  “Willful Blindness” can satisfy either standard ‒ Civil Trade Sanction Violation More Likely Egregious if:  1) Actual Knowledge or 2) Reason to Know ‒ These knowledge standards play different roles in their respective regulations but are conceptually similar ‒ Conduct that satisfies one of the standards is often indicative of a lax compliance environment, which in turn suggests a heightened risk of satisfying the other standard
  16. 16. © 2016 Baker & McKenzie LLP 16 ‒ Failure to identify indirect business activities with proscribed restricted parties ‒ Overlooking broad reach of U.S. jurisdiction ‒ Inadequate screening against restricted parties lists ‒ Application of export and reexport controls for all U.S.-origin products to certain destinations ‒ Failure to conduct sanctions compliance due diligence Common Trade Sanctions Compliance Pitfalls:
  17. 17. 17©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide In-House Perspective 171/2/2017
  18. 18. Russia: From Emerging Market to Persona Non-Grata • Sanctions were imposed rapidly and had immediate legal effect • GD business unit impacted significantly, including its existing relationships and contractual obligations • GD response can impact reputation and publicity • Assess SEC disclosure obligations • Convergence of multiple compliance regimes and process owners • Anti-corruption compliance officers • Export licensing and compliance personnel • AML/Patriot Act Know Your Customer (“KYC”) files • Contracts Department • Risk Management • Accounting/Finance
  19. 19. Russia: From Emerging Market to Persona Non-Grata • Export restrictions • ITAR – denial of licenses, existing TAA/MLAs subject to review • EAR – three types of restrictions – ECCNs controlled for National Security (NS) reasons – no longer favorable licensing policy, irrespective of end use (not limited to oil/gas) – Oil/gas projects (deep water, Arctic offshore, or shale) – 2 separate lists to check – Entity List designations – all items subject to the EAR
  20. 20. Iran and Cuba: Are they Open for Business?! • Cuba – March 15, 2016: CARC and EAR significantly amended • Expand the Ability of Americans to Visit Cuba • Bolster Trade and Commercial Opportunities • Reduce Barriers to Financial Transactions by Cuban Nationals – Multiple FAQs and clarifications, particularly regarding financial transactions – Not really a “game changer” for GD • Iran – January 16, 2016: General License H  very limited permissions – July 29, 2016: General License J  possible opportunities!
  21. 21. Key Question #1: Does the transaction involve any parties located in a sanctioned country? • Sanctions vary in scope depending on country involved • U.S. companies generally may not, without a license, exception or other authorization from the U.S. Government, directly or indirectly: – Export or import goods or software to or from a sanctioned country – Provide services (financial and non-financial) to or retain from such country – Deal outside the US in goods from such country – Deal in blocked/frozen assets or other interests in property – Other broad restrictions include: investments, contracts or other commercial activities, travel (Cuba), etc. – Cannot approve or facilitate any of the above, or knowingly evade sanctions – Applies to entities “owned or controlled” by targeted governments North Korea, Sudan, Syria Belarus, Burma (Myanmar), Central African Republic, Cuba, Democratic Republic of the Congo, Iran, Iraq, Ivory Coast, Lebanon, Liberia, Libya, Somalia, South Sudan, Ukraine/Russia, Yemen, Zimbabwe All other countries
  22. 22. Key Question #2: Does the transaction involve any restricted parties? • OFAC maintains various restricted party lists that prohibit or restrict transactions with identified individuals and entities – Specially Designated Nationals (SDNs) – Foreign Sanctions Evaders (FSEs) – Sectoral Sanctions Identification List (SSIL) • Activities, such as entering into agreements, exports, transfers, banks, transportation, or other similar activities may be prohibited • Restrictions apply to entities “owned” by such parties at 50% or higher level (directly or indirectly) • Restrictions can also be triggered by “control” Restricted parties All other parties provided they are not located in a sanctioned country
  23. 23. Lessons Learned • Critical to act promptly – “Task force” created, regular meetings internally and calls with outside counsel – Communication with the customer and other relevant parties, with legal guidance – Communication to the business about restrictions on blocked aircraft and what/how to communicate with customer/third parties • Information sharing across business functions and subsidiaries – Obtain additional intelligence and/or prevent unauthorized provision of services/support – Identify available information/documentation (e.g., FCPA diligence, AML/Patriot Act KYC files) to obtain additional evidence regarding current ownership/corporate relationship and parties involved
  24. 24. Lessons Learned • Consistent Interaction with OFAC (via outside counsel) – Informal guidance – Filed required blocked property reports – Obtained specific licenses – Reconsideration requests – Assessed additional licensing requirements – Discusses plausibility of other legal strategies
  25. 25. 25©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide ComplianceConvergence 251/2/2017
  26. 26. ©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide 261/2/2017 Common Elements of EffectiveCompliance Programs • Commitment from Senior Management • Risk Assessment • Written Policies • Training • Accountability & Oversight • Screening/Due Diligence • Documentation • Reporting • Monitoring
  27. 27. ©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide 271/2/2017 Leverage ExistingCompliance Program Anti-Bribery • Written Policies • Training • Due Diligence • Audits Sanctions • Use existing policies as guide for developing sanctions policies • Add sanctions training when providing anti-bribery training for employees and 3rd parties • Incorporate sanctions questions into due diligence; utilize beneficial ownership and screening information • Audit for anti-bribery and sanctions compliance in tandem
  28. 28. ©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide 281/2/2017 1. Do business with or provide services to entities in restricted territories? If yes, what types of services? 2. Deal with goods originating from restricted territories? 3. Offices or other operations in restricted territories? 4. Past trade control violations or currently under investigation? 5. Placed on any restricted parties’ lists? 6. Conduct business, directly or indirectly through third parties, in restricted territories without the requisite license in place? Due DiligenceSanctionsQuestions
  29. 29. ©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide 291/2/2017 Recommendations U.S. Parent Company • Review information collected for due diligence for trade sanctions violations to supplement automated screening • Review common compliance program elements, including detection and reporting tools, to ensure they’re being used to address both risks • Train constituents to recognize both anti-bribery and trade sanctions compliance risks within their areas of responsibility, focus training and monitoring on employees with highest risk of violations (e.g., sales), ideally using live in-person training Third Parties • Use risk-based due diligence to assess third parties • Incorporate compliance clauses into contracts to help clarify and enforce obligations under both anti-bribery and sanctions regulations, and request annual attestations of compliance • Implement your compliance program in-region, ensure that executive leadership visibly supports it, and discuss country-specific risks • Conduct remote process reviews and external gap assessments, and request periodic attestations of compliance with due diligence requirements Foreign Offices
  30. 30. ©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide 301/2/2017 Helpful Resources • OFAC Website: www.treasury.gov/resource-center/sanctions • BIS (Bureau of Industry and Security) Website: www.bis.doc.gov • DDTC (Directorate of Defense Trade Controls) Website: www.pmddtc.state.gov • Export.gov: export.gov • Export.gov Consolidated Screening Lists: 2016.export.gov/ecr/eg_main_023148.asp • Baker & McKenzie “Sanctions Update” Blog: www.bakermckenzie.com/sanctionsnews • Baker & McKenzie FCPA Updates: www.bakermckenzie.com/insidethefcpa • TRACE’s Russia/Ukraine Conflict Sanctions Analysis: www.traceinternational.org • TRACEpublic: tpms.traceinternational.org/TRACEpublic • Country Registers: e.g., www.gov.uk/government/organisations/companies-house • Russian Partner Database: russianpartner.biz • ICIJ (International Consortium of Investigative Journalists): offshoreleaks.icij.org • Subscription-based services: Interfax.com & news.riskadvisory.net/sanctioned- individuals
  31. 31. ©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide 311/2/2017 Helpful Resources
  32. 32. 32©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide Networking Break 321/2/2017
  33. 33. 33©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide CaseStudies 331/2/2017
  34. 34. Case Study # 1 You are the Pumpkinseed North America compliance officer. Your business development (BD) director has been courting a prospective sales rep in China, who comes highly recommended by industry peers. You explain the vetting and approval process to the BD director, including the time involved to complete the process. The BD director understands and agrees, but comments the company risks losing out on potential, upcoming business if the sales rep cannot start work right away. You remind the BD director that third parties cannot undertake any work until approved and under contract. In the course of due diligence, you discover that the General Manager (GM) of the prospective sales rep is the nephew of a mid-level official in the Chinese Ministry of Finance. The prospective sales rep, if approved, will handle sales to the Ministry of Transport, which must receive final approval from the Ministry of Finance. You also learn that the BD director and the sales rep have recently had lunch with his nephew to better understand the requirements of the upcoming tender. What do you do?
  35. 35. Case Study # 1, Cont’d… After clearing red flags, the application is approved and the sales rep is now under contract. The rep’s agreed upon commission rate is 5%, but another exciting opportunity has just been announced and the company would like to pursue it. The sales rep indicates it will take a “a lot of leg work” on their part to put your company in front; the sales rep can get the job done, but at a 15% commission for this “special project.” Any increase in commission rate must be reviewed and approved by Compliance. The BD director comes to you with the approval form and says there is no time to waste “with a million questions.” • What issues need to be reviewed? • How far does your review have to go back? • Does your company have an investigation protocol? When do you bring in Legal? • How much do you share with the BD director and/or the sales rep?
  36. 36. Case Study # 2 Pumpkinseed France, via an independent distributor, is favored to secure a contract with Stroytransgaz, a Russian engineering construction company in the field of oil and gas industry, to supply its products. Certain components used in Pumpkinseed France’s products are sourced from a U.S. supplier. Those components are sourced by Pumpkinseed France for its general inventory. Payment from Stroytransgaz, which is a U.S. SDN and on the Entity List but not an EU DP, is due in U.S. Dollars. Accepting payment other than in U.S. Dollars requires approval from Pumpkinseed France’s Finance Director, who is a U.S. national based in France. • What considerations arise from sourcing components from the United States? • Does it matter that they are sourced as part of Pumpkinseed France’s general inventory? • What are the implications of the payment being in U.S. Dollars? • What are the possible risks arising from the Finance Director consenting to the use of a different currency? 36
  37. 37. Leveraging Efficiencies Revisiting each of the hypotheticals, consider how you might leverage your resources to handle both compliance protocols together. • How does the jurisdiction affect the depth of your analysis? Should you always seek to consolidate diligence efforts? • How does one analysis affect the other, i.e., what are you looking for and how do the red flags differ? • How might you simultaneously protect the company from both sets of risks long term? Are there monitoring/ testing efficiencies? • How much diligence is enough diligence? How does the enforcement environment affect that determination? 37
  38. 38. 38©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide Q&A 381/2/2017
  39. 39. Visit us online at www.TRACEinternational.org facebook.com/TRACEinternational linkedin.com/company/ TRACE-international-inc- twitter.com/TRACE_inc youtube.com/TRACEinternational ©2016TRACE International, Inc.Raising the Standard of Anti-Bribery ComplianceWorldwide ThankYou! 391/2/2017

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