What sort of checks should be done to meet FCPA requirements on overseas employees and business associates?
As with any background check program, we are looking for any “red flags” or “signs” such as discrepancies in the individual’s background that could show a pattern of misconduct. First, we validate the individual’s identity to confirm the individual is who they say they are. When dealing with foreign national candidates, this can be accomplished by performing a local ID validation of the individual’s government issued identity documents such as a passport or other local national identity documents. A search of Restricted Parties and Blocked Persons is checked to determine if an individual or business entity may be on a list of sanctions, known fraudesters, terrorists, money launderers, OFAC or consolidated lists, or even linked to politically exposed persons. We would conduct an international criminal record check on the individual from countries they’ve resided. Be aware the time required to undertake an overseas criminal record check may take much longer than what you may be accustome
