10/23/18: In a post on The FCPA Blog entitled, “Dear Intermediaries: Don’t Manufacturer Your Own Red Flags,” Bill Steinman writes,
“I see it time and time again --
third parties that would otherwise pass muster under a client’s due diligence process create their own red flags.”Fortunately, he goes on to list four of the red flags that could have been avoided. At the top of the list: Pushback on local law issues.