Five Lessons for Third-Party Distributor Risk Management from Microsoft FCPA Settlement (Part III of III) - Corruption, Crime & Compliance

Five Lessons for Third-Party Distributor Risk Management from Microsoft FCPA Settlement (Part III of III) - Corruption, Crime & Compliance: The Microsoft FCPA settlement, while not significant in the total penalty of approximately $25 million, provides some important instructions concerning distributor and re-seller risks and mitigation strategies.  Here are five important lessons learned:  Discount Controls and Customer/End User Pricing: Microsoft agreed to provide significant discounts based on false justifications.  Microsoft failed to confirm the justification for the discounts that permitted the bad actors to create...

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