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Most multinational companies today engage Third parties, which can provide them with valuable resources for conducting business throughout the world. Third parties also can provide companies with a high risk of corruption that can lead to potential violations of the Foreign Corrupt Practices Act (FCPA). However, with proper diligence, contractual provisions, training, and oversight, companies can maintain control over FCPA risk and reap the benefits of third parties’ contribution to their businesses.

The FCPA prohibits corrupt payments made through any third party 'knowing' that some or all of the payment will be paid to a foreign government official. Third parties can include agents, distributors, consultants, contractors, and subcontractors. They can also include service-providers, suppliers, and other non-intermediary third parties. The FCPA does not require actual knowledge of a third party’s acts; rather, willful blindness is sufficient to impute knowledge. That means companies cannot simply turn a blind eye or otherwise ignore signs of possible bribery by the third parties