Lessons Learned from McKinsey’s FCPA Enforcement Action — Local Partners and Third Parties (Part III of III)

Volkov – Yogi Berra said it best — we have seen this scenario before, with similar parties — corrupt foreign officials from Eskom (and Transnet), local partner requirements resulting in engagement of unqualified businesses, and corrupt third parties who assist the bribery scheme in exchange for a cut of the action.