In The News

Japan bar association’s anti-bribery guidance 'positive development' – lawyers


22 Jul 2016

James Koukios, a partner in Morrison & Foerster's securities litigation, enforcement and white-collar defense practice group and former senior deputy chief of the Justice Department's fraud section, was quoted in this article regarding anti-bribery guidance and its relevant in treatment of third-party due diligence.

Koukios, a former official with the DoJ’s criminal division, worked on an FCPA case against trading firm Marubeni in 2014. He noted that in the last few years Japanese companies including Marubeni and engineering firm JGC were alleged to have violated FCPA by engaging in bribery via third parties.

“Due diligence of third parties can be an effective way to mitigate anti-corruption risk,” he said, noting that for Japanese and global companies 90% of FCPA cases involved third parties.



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