Stop Worrying About Whether That Company You Want To Buy Has Been Bribing Everything That Moves

Author:
Updated:
Original:

Nobody will hold it against you, sayeth a former DOJ guy who used to hold such things against companies for a living.

I think most companies and their outside counsel believe any potential corruption problem should stop a deal from occurring. Companies would be surprised to learn that neither the Securities and Exchanges Commission nor the DOJ takes that position….

Sometimes there’s a strategic or legal issue with doing corruption due diligence before a deal. If it’s not possible to do it before you can always do the due diligence afterwards….

DOJ and SEC generally recognize that sometimes it’s not possible to do complete due diligence beforehand. However, if there are good faith efforts to conduct due diligence, integrate compliance programs and take remedial actions by removing those wrongdoers — if all of that is done on a quick basis [authorities] give very strong credit.

Former Justice Official on How to Buy Corrupt Companies [WSJ Risk & Compliance Journal]

Related

Being Broke Won’t Stop Dov Charney From Buying American Apparel

The man's a lot of things, but he ain't a quitter.