2 posts
A short, jargon-free guide to FCPA third-party vetting: when the Foreign Corrupt Practices Act applies to your brokers / agents / consultants, what the 16 red flags actually look like, and the difference between a one-off compliance check and a monitored program.
Most PE funds run KYC on the GP and the target. The intermediaries — placement agents, broker-dealers, local consultants — slip through. Here is when that is fine, when it is dangerous, and where to start.