Companies today are increasingly expected to employ a “Know Your Intermediary” (“KYI”) approach to business transactions, similar to the “Know Your Customer” programs that have been a requirement for U.S. financial services companies since the 1970s.

Posted In:


For example, since 2009, 85% of FCPA violations that resulted in regulatory action involved an intermediary – a consultant, agent, distributor, broker, or other party.

In a recent article for Compliance Week, Xavier Oustalniol and Steven Neuman outline steps companies can take to implement an effective KYC program across their global operations.

Read the full article.

About the Authors

Xavier Oustalniol

Xavier Oustalniol

Xavier Oustalniol is a Partner with StoneTurn in San Francisco. He focuses on complex forensic accounting issues, fraud investigations and prevention, and anti-corruption matters, and provides consulting services regarding damages […]

Read Bio
Steven Neuman

Steven Neuman

Steven Neuman, a Managing Director with StoneTurn, has 18 years of experience in advising clients and companies on compliance and risk-related matters, as well as global investigations. He brings significant […]

Read Bio