Possibly. Most FCPA enforcement actions involve third parties. The FCPA expressly prohibits corrupt payments made through third parties or intermediaries. The f

Possibly. Most FCPA enforcement actions involve third parties. The FCPA expressly prohibits corrupt payments made through third parties or intermediaries. The fact that a bribe is paid by a third party does not eliminate the potential for criminal or civil FCPA liability. The FCPA expressly states that a company or individual may be held directly liable for bribes paid by a third party if the principal has knowledge of the third party's misconduct. It is unlawful to make a payment to a third party, while “knowing” that all or a portion of the payment will go directly or indirectly to a foreign official. The term “knowing” includes “conscious disregard” and “deliberate ignorance”. Intermediaries may include joint venture partners or agents. Third parties and intermediaries themselves are also liable for FCPA violations.* *: https://www.transparency.org.uk/wp-content/plugins/download-attachments/includes/download.php?id=5739 https://www.transparency.org.uk/wp-content/plugins/download-...