Sanctions

A mid-sized Netherlands based company was expanding its sales into the Middle East. They hired a local sales team that was performing incredibly well throughout the region. Unfortunately for the company, the local sales team hired an out-sourced service team from a company based in Iran, though they had a large presence in Dubai. OnRamped would have identified the Iranian parent company and alerted the company prior to entering a business relationship with the service team. OnRamped was built to identify issues and risk prior to the reputation damaging event occurs.

 

 

Foreign Corrupt Practices Act (FCPA)

A European multinational doing business in China responds to an RFP from a large Chinese company. Unfortunately, there is no outward indication the company is in large part owned by the Chinese Government. The European multinational then proceeds to build a relationship with the company through expected/traditional methods (i.e. paying for meals, entertainment and gifts). During this time, the Chinese company attempts to negotiate the price down by requesting discounts on the product through an extensive series of emails. Legal is not engaged prior to the formation of a contract, so there is limited to no visibility around the facts surrounding the potential business. The back and forth negotiations prior to the awarding of the bid lead to the European multinational winning the bid. One of the competing bidders for contract ends up losing the bid, then contacts the Chinese, US, and UK regulators to file a complaint against the European company for violating anti bribery and bid rigging laws. Incorporating OnRamped would have identified the fact that the company was controlled by the Chinese Government, despite the fact there were no obvious signs that they were dealing with a government-controlled entity. It would have notified the company that this customer must be treated differently than a business owned by a non-governmental entity. This would have stopped the company from providing gifts, entertainment and meals to a state-owned entity in violation of US, UK, and Chinese law. The OnRamped notification would have also signaled that any correspondence with the customer after the bid is submitted and before the contract is awarded is prohibited under Chinese law.

 

 

Bribery

A mid-size US company has an established sales force in the US, however the company would like to expand to Europe.  The company has low visibility in Europe, so they hire a sales agent to sell products on behalf of the company.  The contract is finalized, and the sales agent is allocated a marketing and sales budget to build brand awareness. Unfortunately for the company, the sales agent was very effective for prior companies due to his practice of paying cash bonuses to purchasers.  The regulators start investigating a bribery allegation at another company the agent worked for in the past and traced him to the US company. OnRamped would have performed a background check on the agent, identified prior newspaper articles on his methodology.  Equally as important, prior to issuing a contract, he would be required to read and sign a series of documents acknowledging he would abide by the company code of conduct as well as US and international laws.  Once the regulators approached the company, they could provide all the documents and demonstrate the diligence the agent was required to go through prior to hiring him.  A well document process is crucial to surviving a regulatory inquiry, and that is precisely what OnRamped is set up to do.