Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Third parties definition

What does Third parties mean? In legal practice, third parties are persons or organisations that are not the principal parties to a contract, dispute, or data-processing activity but may interact with or be affected by it. The term is descriptive across contexts. In data protection law it is defined: a third party is anyone other than the data subject, controller, processor, and those acting under a controller’s or processor’s direct authority (UK GDPR/EU GDPR). cookies and similar technologies: if a service permits third parties (for example, advertising, analytics or social media vendors) to set, read or access cookies or other identifiers, those third...

US FCPA: managing third‑party anti‑bribery risk with due diligence, contractual controls, training and oversight; SEC books and records and internal controls obligations

Published by a LexisNexis Corporate Crime expert

Practice notes

ARCHIVED: This archived PrACTice Note is not being maintained.

Today, most global businesses work with Third parties, tapping into vital capabilities that help them operate across markets. Yet those relationships can also carry significant corruption exposure, potentially resulting in breaches of the Foreign Corrupt Practices Act (FCPA). With the right diligence, tailored contractual terms, targeted training, and robust oversight, organisations can manage FCPA risk while still benefiting from third-party contributions to their operations.

The FCPA bars corrupt payments made through intermediaries when a company is ‘knowing’ that some or all of the money will be passed to a foreign government official. It is not necessary to have actual knowledge of a third party’s Conduct; wilful blindness can be enough to attribute knowledge. In practice, businesses cannot look the other way or disregard indications of possible bribery by those they engage.

Agents, distributors, consultants, contractors, and subcontractors
Service-providers, suppliers, and other non-intermediary third parties

Effective third-party engagement should include anti-corruption due diligence, carefully drafted contractual protections, appropriate training, and continued oversight and monitoring processes to ensure that...

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Web page updated on 22/05/2026

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