FCPA Compliance Report

Brandon Daniels-Ongoing v. Point in Time Due Diligence


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In this episode of the FCPA Compliance Report, I visit with Brandon Daniels, President of Exiger. Brandon is a long-time favorite on the FCPA Compliance Report and he always brings a unique perspective to a variety of compliance topics. In this episode, we look at the Theranos case from a very different angle than the criminal fraud trial of Elizabeth Holmes. We consider the due diligence lessons from Theranos. Highlights of this podcast include:


  1. What is the difference in ongoing due diligence v. point in time due diligence? 
  2. How does Due Diligence on potential investments different (or not) from DD on other types of 3rd parties?
  3. What type of areas should you look at in DD of potential business partners/investments?
  4. How do you perform DD on leaders or senior management of potential business partners/investments?
  5. What people or skill sets should be on your DD team? For instance you would you suggest have been on a DD team to evaluate Theranos?
  6. How do you evaluate the risk or are you simply trying to ID red flags?
  7. Does DD provide insight into the leader of a potential business partners/investments continuing after the deal is done?

  8. Resources

    Brandon Daniels on Exiger website

    Pre-investment, IPO and Fund-Raising DD

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    FCPA Compliance ReportBy Thomas Fox

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