Companies’ FCPA compliance programs have generally focused on agents and freight forwarders, the types of business partners that tend to get in trouble with the law. Increasingly, however, companies are scrutinizing suppliers as well.
Due diligence of suppliers is becoming tougher; traditionally they have had to undergo only minimal credit checks, but now they are being chosen and reviewed much more carefully. And suppliers increasingly have to sign contracts that give their customers the right to audit them, and may also include an indemnification clause.
via FCPA Third Parties SEC Compliance.–CFO Magazine