As part of its FCPA-focused compliance review of agents, suppliers and distributors, a US multinational engaged Nardello & Co. to conduct due diligence on its representative in Indonesia, a high-risk jurisdiction from its perspective given the endemic corruption within the country and the company’s targeting of government construction contracts there.

The investigation entailed an in-depth interview and assessment of the agent in person as well as discreet enquiries into his background and reputation. Our findings identified a number of potential FCPA concerns, the most significant of which involved the agent taking government clients on fully paid “fact-finding” trips to Las Vegas and other US and European destinations.