To the untrained eye, they often appear as scrubby derelict vagabonds, haunting the steps of administrative offices throughout the developing world. Yet, this unassuming guise belies their predatory importance as quasi-official intermediariesserving as both roadblocks and essential intercessors. They are “touts,” and if your company has ever obtained official documents in West Africa, touts have likely paid cash to government officials on your behalf. And with or without your knowledge, touts may have caused your company to violate the Foreign Corrupt Practices Act (FCPA).
‘Enforcement 40’ for 2020
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