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.
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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 outlines steps companies can take to implement an effective KYC program across their global operations.
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 […]
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