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Third party agents and consultants present some of the most dangerous pitfalls for companies looking to minimize their FCPA and anti-corruption risk. When companies conduct business through an agent, the companies relinquish a certain degree of control over their processes, and lose some measure of transparency in their anti-corruption compliance program. In spite of these process and program limitations, the FCPA and other anti-corruption laws may still hold a company liable for corrupt payments made on its behalf, even though the company has a diminished ability to police such corruption.