Travel Agencies Are Third Parties Too
Companies doing business in the global marketplace engage all types of third parties. Generally, Foreign Corrupt Practices Act compliance tends to focus, with good reason, on third parties such as agents, representatives, distributors and others that assist a company in obtaining or retaining business.
However, given the DOJ and SEC’s broad interpretation of that key element of the FCPA’s anti-bribery provisions, any third party that has a point of contact with a foreign official – even if outside the context of foreign government procurement – can potentially expose a business organization to scrutiny and enforcement.