Mitigating Risks and Recognizing Red Flags in India’s Landscape of Persistent Corruption

India has featured prominently in several U.S. and foreign enforcement actions, including the 2019 Cognizant and Walmart settlements. At a recent Strafford webinar, Jay Holtmeier, a partner at WilmerHale; Elizabeth Keating, vice president and chief ethics and compliance officer at Gemological Institute of America; and Jeffrey Everson, senior manager at EY, discussed the corruption landscape in India, evolving modes of bribery, mitigation techniques and red flags to look for. “While I’ve seen certain concrete improvements, the waters are still choppy and you can find your ship heading toward the rocky cliffs in the blink of an eye,” Keating said. See “Regional Risk Spotlight: Jay Holtmeier of WilmerHale Explains How to Navigate Bureaucratic Corruption Risks in India” (Sep. 23, 2015).

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