On 24th May, Nyman Gibson Miralis published an article about a recent white paper from TRACE International outlines some of the key red flags that may signal a heightened risk of foreign official bribery when dealing with intermediaries.  It highlights the importance of obtaining all relevant information that may be able to help companies to conduct thorough due diligence and make informed decisions about appropriate safeguards to put in place when dealing with third parties.  The red flags include government links; history and reputation of the intermediary and its personnel; inadequate controls at the intermediary; where the intermediary does not have any clear expertise in the relevant industry, or adequate human and financial resources; where there is missing or inadequate information; and intermediaries which are outright unco-operative in providing requested information.

The TRACE white paper is at –

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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