And what about the vendors?

“U.S. Considers Role of Banks, Sponsors in Soccer Bribery Probe,” The Wall Street Journal, April 18, 2016.  Internal and external criminal investigations look at “sponsors, broadcasters and banks” (11 multi-nationals) in connection with bribery in international soccer.

Corruption can involve lots of different people, not all of whom are in your company.  Does your risk assessment consider the risk of one of your customer’s other vendors paying bribes?  You still get rolled up in the investigation, even though you may be blameless.

If your customer takes bribes, watch out.