“Red flag” is a term of art in the FCPA/anti-corruption compliance world. The presence of a red flag does not necessarily mean that illegal conduct has occurred or that the Company has legal exposure if it proceeds to engage a particular third party (e.g., agents, accountants, consultants, sales representatives, distributors, attorneys, travel agents, or other business partners). Rather, red flags indicate that the Company should take a closer look at the issue to determine whether there is anything truly suspicious or whether instead an acceptable risk is presented in the context of a particular third-party relationship.
