Foreign Corrupt Practices Act Red Flags Checklist

Summary

This Foreign Corrupt Practices Act (FCPA) red flags checklist provides a review framework for use (1) in the due diligence process for selection of an international representative, consultant, agent, or distributor (each an intermediary); and/or (2) during the course of a relationship with an intermediary. Red flags may concern an intermediary’s reputation, ties to government, capabilities, compensation, or other questionable circumstances.