Open an FCPA third-party due-diligence file

Practice the sequence you already learned for “Open an FCPA third-party due-diligence file” until the order feels automatic. Drill DOJ / FCPA resource-guide order from ethics-and-compliance training. The intermediary is not engaged until ownership, red flags, and contract clauses are cleared.

1. Identify the third party's beneficial owners.
2. Identify government touchpoints.
3. Run the taught screening and questionnaire.
4. Escalate red flags: success fees, opaque owners, or requests to pay a relative of an official.
5. Obtain the required committee approval.
6. Execute the contract with audit, termination, and anti-corruption clauses.
7. Do not pay a commission until that file is complete.