The U.S. Securities and Exchange Commission (“SEC”) has two new weapons in its transparency and anti-bribery arsenal – rules that impose new obligations on companies that file reports to the SEC and work in jurisdictions with a high incidence of corruption. These new rules serve to further reinforce the notion that effective compliance programs, including third-party/supplier due diligence protocols and monitoring of third-party payments, are critical to effective risk management when doing business in countries where corruption is prevalent.

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