8-15 Ton Duc Thang Street, Dist. 1
Ho Chi Minh City
Viet Nam
Managing FCPA risks from using or acting as a third party intermediary Kara N. Brockmeyer, the chief of the U.S. Securities and Exchange Commission’s FCPA unit commented at a conference in November 2013 that more than 60 percent of the SEC’s cases in the last two years involved third-party intermediaries.