This is an old article but one that should be studied to appreciate what you shouldn’t do in the international marketplace.

Back in 2021, Deutsche Bank agreed to pay $130 million largely to settle allegations that it violated laws against bribery by using middlemen and hiding its payments to them as part of a global effort to win business.

Let me repeat the key part of what they did wrong:  They violated laws against bribery by using middlemen and hiding its payments to them as part of a global effort to win business.

The article goes on to say:

The bribery settlement exposed a wide-ranging effort by the bank to use consultants or middlemen to help it get deals in Saudi Arabia, Abu Dhabi, China and Italy. Regulators frown on the use of these consultants because they are often seen as a backdoor way to funnel cash to government or corporate officials.

Since then, Deutsche Bank has said it has committed significant resources to improve its money-laundering controls and has fully cooperated in investigations.

Read the entire article here.

I write more about bribery – what it is, about the Foreign Corrupt Practices Act (FCPA), how to stay clear of trouble and what you should do if you are part of a bribe, here