Embraer Uses Sleight-of-Hand Payments to Third-Party Agents to Sell Planes Around the World, Landing It More Than $200M in U.S. Fines
“Hiring consultants after a transaction has already been negotiated, or agreeing to pay additional or larger commissions, is always a red flag,” said Luke Cadigan, a partner at Cooley. “In some circumstances, there may be legitimate reasons for doing so, but those circumstances should be scrutinized very carefully.” Carvalho agreed, noting that “a very thorough explanation would need to be presented to the compliance department in order for it to clear the transaction.”
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