Addressing corporate fraud and corruption in Africa
August 2012 | TALKINGPOINT | FRAUD & CORRUPTION
FW moderates an online discussion on addressing corporate fraud and corruption in Africa between Reagan R. Demas, a partner at Baker & McKenzie LLP, Petrus Marais, a partner at KPMG, and Robert Driman, a director at Norton Rose.
FW: From your experience, what seems to be the prevailing global perception of fraud, corruption and bribery when it comes to conducting business in Africa?
Marais: One does not have to look further than the countries included in the bottom half of Transparency International’s annual Corruption Perception Index to realise that the majority are located on the African continent. Transparency International conducted a further study in Southern Africa in 2011 to ascertain the public’s perception on the corruption levels in the countries and the governments’ effort to fight corruption. The study titled ‘Daily Lives and Corruption: Public Opinion in Southern Africa’ included face-to-face interviews with over 6000 people in six Southern African countries, namely the Democratic Republic of Congo (DRC), Malawi, Mozambique, South Africa, Zambia and Zimbabwe. According to the study, 56 percent of people surveyed in these Southern African countries stated that they have paid a bribe in the last 12 months. The study indicated that 62 percent of the people surveyed believed that the corruption levels in their countries have increased in the past three years and the Police Services are perceived to be the most corrupt institution in these countries. In our dealings with the US Department of Justice (DOJ) it is apparent that they view Africa as a high risk location. In summary therefore, we are of the view that these personal experiences, as well as the surveys and literature on the subject, do confirm and to an extent perpetuate the perception of there being high levels of bribery and corruption in Africa. However, one must be reminded that this perception also applies to most of the BRIC countries and other high growth markets.
Demas: Despite the precarious global economy and the cloud of uncertainty lingering over global economies, Africa remains a continent of great opportunity for investors. The continent weathered the downturn better than the West and GDP growth rates are some of the highest in the world. Yet the prevailing view is that corruption and poor rule of law in Africa prevents companies from operating and obtaining quality returns on investment on the continent. This view prevents many from pursuing opportunities in Africa, but the reality is that companies that effectively assess and minimise risk achieve on average higher returns on African investments than they obtain anywhere else on earth. The key to success on the continent is to properly identify those risks and take appropriate steps to protect your investment in advance. Africa remains one of the last ‘economic frontiers’ on earth and can be highly profitable for companies that take a smart approach and seek knowledgeable counsel.
Driman: The Western perception is that doing business in Africa is rife with corruption, particularly when dealing with government officials. There are countries where this is true. However, there are many shining exceptions – the tiny Kingdom of Lesotho famously acted against multinationals and their employees for corruption in its Highlands Water Scheme project. Countries like China and India have made huge commercial inroads in Africa by not accepting prevailing Western perceptions. The reality is that Africa is not nearly as monolithic, nor is doing the right sort of business as different, as is often perceived globally. There are many examples of excellent legitimate business propositions in all industries. Because it is resource-rich, there is the temptation to secure lucrative deals by going outside of acceptable norms. The best advice for businesses is to conduct business as in any well-regulated jurisdiction. A pre-deal territory due diligence is often advisable.
FW: To what extent does enforcement of extraterritorial laws such as the US FCPA and the UK Bribery Act affect the African operations of multinational companies? What is the practical impact of such enforcement?
Demas: Enforcement of US extraterritorial bribery legislation – the FCPA – has dramatically escalated in the past decade and shows little sign of abating. Other countries have passed similar legislation and are beginning to enforce those new laws. The African continent has been in the crosshairs of numerous investigations due in part to the perception by regulators that the rule of law is weak on the continent. In the wake of criminal settlements with companies operating in Africa in the oil & gas, mining, telecommunications, freight forwarding and other industries, businesses are recognising the importance of a well-developed compliance program when operating in these higher-risk/higher-reward jurisdictions. Given the scrutiny on businesses operating in Africa, companies are well-advised to ensure they have absorbed compliance best practices into their Africa operations before a problem arises. While these measures do result in additional front end costs for the investment, few companies regret such an investment in ethics and compliance. In Africa, that investment pays for itself down the road.
Driman: Fraudulent and corrupt practices are gradually being marginalised. These new laws mean that proscribed behaviour is punishable in the legislating jurisdiction. Multinationals are accordingly very reluctant to transact in countries with poor records on governance. Investors know that the early profits from improperly obtained business are soon outweighed by reputational and legal impediments. Old practices of facilitation or similar fees, which have no proper commercial basis, are declining. Advisers who have only political influence and no business role are less influential. There is much more emphasis on early due diligence. Existing business is more carefully scrutinised and audited, and investors in multinational businesses and funds are in turn much more critical in assessing underlying investments in Africa.
Marais: Africa has seen its share of FCPA enforcement actions by the US DOJ and the US Securities and Exchange Commission (SEC). Multinational companies such as Alcatel-Lucent (France), Panalpina (Switzerland), Daimler and Siemens (Germany), BAE (United Kingdom) and others in the recent past have received hefty fines and penalties with relation to their operations in African countries such as Nigeria, Ghana, Angola, and others. The nature of the violations centre mainly on payments made to government officials and the use of third party intermediaries to secure contracts. While many of them have involved the oil and gas industry as well as customs and logistics third parties, it is anticipated the DOJ and SEC will continue to focus on Africa across all industries. These FCPA enforcement actions emphasise the fact that multinational companies can no longer take a ‘head in the sand’ approach when it comes to their operations or their relationship with third parties in Africa. The FCPA makes it unlawful to make a payment to a third party, while knowing that all or a portion of the payment will go directly or indirectly to a foreign official. The term ‘knowing’ includes ‘conscious disregard’ and ‘deliberate ignorance’. In practice this means that multinationals must have procedures and processes in place to manage the risk of bribery and corruption in order to be in a ‘defendable position’ vis a vis the legislation.
FW: Within Africa itself, have there been any significant legal and regulatory developments to tackle domestic bribery and corruption?
Driman: Many African jurisdictions have laws dealing to some extent with domestic bribery and corruption. South Africa is an example of a jurisdiction with advanced legislation dealing with money-laundering, organised crime and economic crimes. The challenge for Africa is enforcement. Therefore the role played by international businesses and banks in monitoring the source of funds and suspicious activities, and extra-territorial laws in other jurisdictions where a multinational may operate, are increasingly helpful to authorities who are trying to limit corrupt activities. Foreign businesses should ensure that their dealings comply with best practice, and contracts should have enforceable provisions dealing with the incidence of corruption. Governments across the continent have fallen due to the citizenry becoming disenchanted with corrupt and anti-democratic practices. Businesses which do not comply with best global practice are finding the short-term gains turned into long-term liabilities – along with international business censure.
Demas: Efforts to restrain the ‘demand side’ of corruption – public officials who demand bribes to perform duties – are ongoing and have been substantial. Many Africa states have strict laws criminalising corruption by officials and even laws prohibiting the payment of bribes – the ‘supply side’. But as Cervantes wrote in Don Quixote, “Laws go as Kings like”, and these domestic laws are simply words on paper if not enforced by local officials. While companies and investors alike operating in Africa would love to see greater local enforcement of anti-corruption laws against officials, such enforcement is still lacking. Regulators in the US, UK, and other jurisdictions that have passed extraterritorial anti-bribery statutes view this failure of local African legal systems to effectively prosecute and deter public corruption as yet another reason enforcement of FCPA-type legislation is important in the fight against corruption in Africa.
Marais: It is important to bear in mind that Africa is not one country, but over 50 sovereign states, each having different circumstances and a different risk profile. In recent history, various African countries have stepped up their efforts, including new or amended anti-corruption legislation, to combat instances of fraud and corruption. The South African government has, in recent years, stepped up its anti-corruption initiatives, which include a national anti-corruption programme aiming to provide leadership against corruption, promote ethical practices, implement anti-corruption frameworks, and provide platforms for all sectors to engage on issues of corruption. However, tackling bribery and corruption is not only about the appropriate legislation and regulation. To be effective there needs to be enforcement by the regulators and enforcement agencies.
FW: Could you outline some of the red flags that companies need to monitor in connection with gifts, hospitality, entertainment and travel?
Marais: Expenses related to gifts, hospitality, entertainment and travel may constitute a violation of the FCPA and the UK Bribery Act if coupled with the corrupt intent to obtain or retain business. Some of the red flags which companies need to monitor are as follows. Gifts provided in the form of cash or gift cards which are easy transferable. Requests for gifts in accordance with local ‘customary law’ rather than written law. Requests from government officials to stay in lavish hotels as part of official country or site visits. Requests from government officials to be accompanied by spouses or family members on official visits. Expenses not directly related to the promotion, demonstration, or explanation of products or services. Regular expenditures in favour of government officials. Specific requests by public officials not to follow the organisation’s anti-corruption policy and procedures. Non direct travel, usually including side trips. Payment of travel expenses not made directly to the travel service provider. Travel expenses made directly by staff and reimbursed requested later. This is not a finite list, but provides some examples.
Driman: Prior insight and advice is necessary since jurisdictions and businesses differ culturally. Some multinationals will not allow their staff to accept or give any gift or hospitality, no matter how small in value, and this applies to their African operations equally. In some instances, cultural issues dictate the exchange of some form of gift, usually of nominal value, although depending on the recipient, this may need to be recorded. Businesses need to due a proper investigation into a jurisdiction in advance. As a general rule, where anything out of the ordinary is solicited a red flag is automatically raised. A key consideration here is whether it could be said that something of value was given to exert influence. Reporting obligations may also apply, so businesses need to have both their own internal rules and compliance processes in place.
Demas: The African continent presents unique gift and entertainment challenges. In some instances, community groups or leaders, including tribal chiefs, have made requests for contributions by companies operating in those communities. These requests stem from the belief that companies should be supporting the local community, but they must be handled carefully as it is often unclear who is making the request and how funds provided are ultimately distributed. Failure to respond to such requests to support local communities has resulted in security problems for foreign companies, particularly companies operating in extractive industries. Where tribal chiefs or local officials are clearly involved in such requests, companies can negotiate ways to support the community without providing direct financial gifts – for example, constructing a school building or making in-kind contribution to support health and education. Other requests from officials come in the form of reimbursement or per diem requests relating to mandated audits or site visits. Some companies have encountered challenging scenarios where African regulatory authorities – for example, tax, immigration or commerce – have initiated audits and requested travel to US or European head offices for lengthy trips to review original documentation. In addition to travel costs, officials in some of these cases have requested large per diems or reimbursement of all expenses; in at least one recent case where the company pushed back on the per diem request, local authorities threatened to shut down local operations and impose significant fines. In the end, while such audits and even reimbursement of certain expenses are often authorised by local law, companies should be familiar with applicable rules and regulations and ensure that any payments or travel provision comport with local law. Retention of knowledgeable local and international legal counsel will usually lead to resolution of such situations amicably and in compliance with applicable laws.
FW: What risks might arise when using third party intermediaries in the region?
Demas: Anti-corruption risks associated with the use of agents and third parties are well documented. In Africa, these risks are heightened by poor public records and the lack of information sources that make conducting thorough due diligence difficult. Monitoring agents obtaining visas and work permits can be particularly challenging, where lack of information on the law and expediting solutions offered by third parties can be frustrating and, in the worst case, a source of FCPA liability. Customs and freight forwarding activities are also a source of risk – customs brokers must be local entities or individuals in many countries and registration is often reserved for former officials and their friends and family. A recent FCPA investigation in one Angolan city revealed that both registered customs broker options in the local port had direct ties to current public officials. In this environment, thorough due diligence and monitoring become crucial elements of any anti-corruption risk management strategy.
Driman: Many businesses use professional advisers which can introduce them to and manage their business with the growing ranks of flourishing independent intermediaries or local professionals in most African jurisdictions. Fees and services must be agreed in advance, and be clear. The value of any service needs to be connected with a legitimate business activity. An absence of such advisers in a country is evidence that business there may be risky altogether. The use of politically-connected intermediaries is an area of considerable risk, particularly if the intermediary brings nothing else to the transaction. As with anywhere in the world, the more corrupt a jurisdiction is, the more likely it is that such relationships will be short-lived and damaging. When using a third party intermediary, the principal must be very clear that it will not tolerate any unlawful behaviour and require the intermediary to abide by the principal’s anti-corruption policy.
Marais: The use of third parties or third party intermediaries (TPIs) can take on various forms and shapes, including sales agents, brokers, consultants, legal advisers, lead generators, and so on. TPIs are one of the highest risk areas for FCPA violations in Africa because multinational companies may be liable for FCPA violations of third parties who represent their company. Adopting a ‘head in the sand’ approach is not a successful method for avoiding FCPA liability and mitigating risk. Some of the risky areas where TPIs have been implicated in the past in Africa are securing in-country real estate for operations, obtaining construction permits and licences, facilitating health and safety inspections and clearing imports and exports at customs. It must be remembered that public records and business histories of parties being dealt with may not be readily accessible and additional effort needs to be made to vet the track record of a TPI.
FW: To what extent do mergers & acquisitions, or even joint ventures and dealings with business partners, need to be examined from a bribery and corruption perspective?
Driman: International advisers have rapidly increased due diligence capacity in M&A, joint ventures and other relationships. The very wide ambit of extra-territorial legislation such as the FCPA, and the increased likelihood of claims arising from corrupt business activities, means that every business needs to apply its best practices in any form of transaction or relationship. African business transactions are no different, and if the right checks and balances are applied, they need not be unduly onerous or cause lengthy delays. The key is to prepare in advance. Pre-clearance of potential business partners, from an anti-bribery and anti-corruption point of view, is essential. Transactors frequently complain of the delays that come with compliance. A transaction which requires the bypassing of normal business processes in itself raises a red flag. In turn, agreements must adequately comply with remedies and enforcement when corrupt activities are either hidden or arise.
Marais: One of the biggest issues any multinational faces prior to any form of M&A activity in Africa is having to consider the possible bribery and corruption history of the target entity. This is especially relevant in the case of US companies or multinationals with US links as the companies might be exposed to ‘successor liability’ for any past bribery and corruption violations of the target entity. In addition, multinationals also have to be cautious of any reputational issues or negative media reports relating to their new business partners or JV partners. As a result, the due diligence needs to go beyond just financial history in order to thoroughly assess the risks.
Demas: ‘Local content laws’ often require that foreign companies enter into a joint venture or other formal relationship with a local company to compete for contracts in certain sectors. Even where a formal local partner is not required, state-owned oil companies, such as NAPIMS in Nigeria, frequently retain significant control over the operations of foreign companies. For example, the state-owned oil company in Angola – Sonangol – has absolute power to approve or reject the award of certain contracts and subcontracts relating to offshore drilling blocks. Recent cases have documented instances across Africa where officials responsible for approving contracts requested payoffs in exchange for approvals. In one case, when the US company approached the official requesting a payoff to approve a block of contracts and informed him of the FCPA, the official reportedly responded “we know how to handle the FCPA” and pulled out a predrafted ‘side agreement’ with a fake third party vendor for the US company representative to sign. The request that foreign parties to state contracts sign ‘side agreements’ with unknown third parties is not uncommon. In one case, a foreign company bidding on an infrastructure project in Libya in 2010 learned that it had won a $500m tender, only to be told that the last step in the process was for the company to sign a multi-million dollar side agreement with an opaque third party for ‘assistance provided’ on its tender bid. Of course, the third party had provided no such assistance and was not even known to the company; after earnest efforts to conduct due diligence on the third party were rebuffed, the company was compelled to walk away from a lucrative contract. Other African states that may not require formal joint ventures with locally-owned entities will require that foreign companies operate through locally-registered subsidiaries with minimum capital requirements and local directors. These requirements can increase the risk exposure for US entities operating in sub-Sahara Africa and require vigilance in monitoring compliance with local corporate laws as well as the actions of local directors and shareholders.
FW: While many emerging markets pose corruption risks to company operations, what challenges may companies face that are unique to the African continent?
Marais: Conducting business on the African continent poses some unique corruption risks to multinationals. In various African countries, public officials would require certain payments to be made based on so-called local customary laws. These payments would generally be in the form of a gift or a donation. Indigenisation quotas or minimum local shareholder requirements can compel a company to take local partners on board, often on the recommendation of government and on favourable financial terms to the local party. Foreign companies generally are not allowed to purchase real estate in the majority of African countries. Therefore, these companies are left to enter into some form of lease agreement with local land owners. Some of these land owners could be public officials and it is not always possible to determine the details of the actual owners as ownership records are not always publicly accessible. To maintain proper accounting books and records in some African countries can also pose difficulty, mainly due to poor record-keeping and inadequate internal controls. In addition, poor or over congested infrastructure creates logistic complexity, particularly when there is an expectation that there be financial facilitation ‘to get things moving’. While there are many risks, the economic growth of most Africa markets, which is predicted to be in the region of 5 percent per annum for the next number of years, makes it difficult for multinationals to ignore the African opportunity. Africa has a young population of about 1 billion people, a rapidly growing consumer class, resource wealth and huge agricultural opportunity, all contributing to its attraction as an investment destination. But regional complexities across the continent demand accurate insights into local risks.
Demas: The African continent presents unique security issues that require effective but realistic solutions. It is generally understood that where individuals are placed in a situation where they reasonably believe they face imminent physical harm or illegal detention, a payment to officials to escape such a scenario is not conduct likely to be charged by regulators. In practice, managing expectations regarding these payments are difficult and personnel should be discouraged from making payments to police, customs, or other officials at the first feeling of discomfort. The personal safety payments exception should never be seen to condone ‘convenience payments’ when personnel are pulled over for speeding or talking on cell phones, or even where company vehicles are pulled over for no valid reason at all, unless the situation escalates to the point that a reasonable person would believe physical harm is imminent. The more common scenario, as experienced in the Democratic Republic of Congo recently, is where company vehicles are pulled over for minor or ‘made up’ violations – for example, mud on tail lights – and the officer threatens to fine the driver or impound the vehicle unless a cash payment is made. While these scenarios would not be seen by US regulators as instances where cash payments to officials were warranted from a personal safety standpoint, each company should have clear, narrowly-defined policies governing payments under duress and, most importantly, any such payments should be transparently documented in the company’s books and records.
Driman: Africa is resource-rich, and business which is attractive to multinationals is likely to be highly lucrative and long-term. Early gains taken by cutting corners are unlikely to produce long-term results. Contracts may require terms dealing with enforcement under one of the international arbitration regimes if enforcement could be otherwise be problematic. The biggest challenge however lies in seeing all of Africa as being the same, and in underestimating African business which has developed significantly. There are significant national, regional and continental differences culturally, politically and economically. The fact that enforcement of international best practice may be lacking in many African jurisdictions may lead to the temptation for less scrupulous corporations to use corrupt methods to secure or retain business. This could be fatal, given the extraterritorial reach of legislation such as the FCPA and UK Bribery Act.
FW: Risk management controls and defences are essential for any business. What considerations should companies make when implementing an anti-corruption compliance framework and whistleblowing procedures in Africa?
Demas: Your people on the ground in Africa will always be your best compliance resources. Train personnel to be vigilant and persistent on anti-corruption matters. The most successful companies operating compliantly in Africa develop personnel who do not accept “it’s just the way business is done in Africa” as an excuse and never presume that improper payments, however small, are necessary to succeed on the continent. In one case, a company operating in Africa was told by the head of its Equatorial Guinea subsidiary that it was impossible to obtain a visa locally without making an unofficial payment, only to learn later that nobody in the company had ever actually tried obtaining a visa without making the payment. Another best practice is to develop and leverage good human compliance resources by rotating personnel. Managers who succeed in developing and maintaining compliant operations in one country can draw on their experience to solve seemingly intractable problems the company may face in another country. And ensure the personnel you have in Africa have experience in the region so they can effectively assess and manage the unique risks. This applies to outside counsel as well; in one case, outside counsel from the US for a large multinational oil services company arrived at the company’s compound in Luanda, Angola with a large, heavily armed South African guard. Both were quickly run off the premises by the company’s angry personnel, who lived in the compound without personal guard and saw the scenario as evidence that outside counsel had little or no experience in sub-Sahara Africa.
Driman: Many businesses have global risk management processes tailored to local circumstances. The same is advised equally in Africa. Representations and warranties, with enforceable breach provisions, should be incorporated in agreements. Business partners and third party service providers and intermediaries must either demonstrate unequivocal commitment to international best practice when it comes to anti-corruption compliance or be required to subscribe to the policies and procedures of the principal. Businesses need to know what the reporting obligations in the different jurisdictions are, and to comply even if enforcement seems problematic. There may also be international compliance issues. Group compliance and risk management policies for Africa ought to be the same as in any other part of the globe.
Marais: First and foremost, the implementation of an anti-corruption compliance framework in Africa requires the full support of an organisation’s top management, both at holdings and subsidiary level. There is no use in having a ‘paper programme’, which top management does not ascribe to and is not evidenced by their decision making and actions. This non-compliant or lip-service attitude ultimately filters down to middle management and lower level employees, resulting in a ‘checklist compliance culture’ which does not stand up to the rigour of legislative enforcement. Another important factor is to ensure that the anti-corruption compliance framework is properly communicated to all stakeholders and that all staff and TPIs receive proper and regular training. Regarding the use of a hotline or whistleblower mechanism in Africa, organisations should ensure that incidents are reported in a confidential manner and all whistleblowers are protected from any form of victimisation. Furthermore, it is necessary to understand how employees in that culture prefer to report allegations.
FW: Considering the tightening regulatory regime, what advice would you give to foreign companies doing business in Africa?
Driman: No better sign exists for doing business in Africa than that countries across the continent are aligning themselves with the global regulatory climate. There are incredible opportunities in Africa, and being able to bring them to fruition means that regulation across the continent has to fit with global best practice. The first rule is that if the deal or its negotiation seems unusual, then it almost certainly is, and extra care and outside advice is required. Increasingly foreign companies report that they are successfully connecting with business being done in Africa in the same manner it is done anywhere else in the world. That, together with significant growth, is also our vision and experience.
Marais: One of the biggest challenges for companies operating in Africa is striking the balance between acceptable conduct in terms of the local business environment, on the one hand, and ensuring compliance with international anti-corruption legislation such as the FCPA and the UK Bribery Act, on the other. With various foreign and African companies currently operating in or being listed on foreign stock exchanges, they also need to consider the impact of, and ensuring compliance with, all applicable anti-bribery and corruption legislation. No new territory is without its challenges for a company looking to penetrate the market. If the challenges are unique on the African continent, then the potential is in the same class. It is imperative to always remember that Africa is a continent of patriots who are proud of their countries and cultures. It is critical that foreign employers gain knowledge of the cultural beliefs and practices of the people in an African country and respect them. The key to doing business in Africa was succinctly summed up in an article entitled ‘How to Succeed in the African Market’: ‘Be mindful of the three Ps of African business: pensiveness, patience, and perseverance. Pensiveness demands the use of common sense. Success demands a lot of patience. Above all, you must persevere and be persistent, but polite.’ We add a fourth P – Preparation. Preparation entails understanding the local market, doing detailed due diligences, and knowing and vetting your local partners, suppliers, and employees.
Demas: Demonstrated commitment to compliance is a growing competitive advantage for companies operating in Africa. On a continent where local laws are often absent or confusing and an understanding of cultural context is vital, the most important weapon a company can have in its compliance arsenal on the African continent is reliable and trustworthy legal counsel. Foreign companies that succeed in Africa recognise the importance of working with a global legal firm with demonstrated expertise on US, UK and EU anti-corruption laws, as well as on-the-ground experience and contacts with reliable local counsels across the African continent, to ensure seamless advice. Despite the often daunting anti-corruption hazards of working in Africa, the continent offers substantial opportunities for companies that effectively identify and manage those risks.
Reagan R. Demas is a partner at Baker & McKenzie LLP. He has significant experience working on behalf of companies and investors conducting work or business in developing countries, with particular focus on Africa. He has worked on the ground evaluating investment and business opportunities with greater clarity and conducting investigations and due diligence on behalf of clients worldwide. Mr Demas has also written and spoken extensively on corruption, compliance issues and how to do business in Africa. He can be contacted on +1 (202) 835 1886 or by email: email@example.com.
Petrus Marais is Global Head of KPMG Forensic. Mr Marais founded a dedicated Forensic practice at KPMG South Africa in 1993. He was appointed to the KPMG International Forensic Steering Group in 1997 and participated in the drafting and roll-out of the Global Forensic Strategy for KPMG. Mr Marais was KPMG Regional Forensic Chairman for Europe Middle East and Africa (EMA) from October 2002 to Sept 2006. In this role was responsible for the development of Forensic practices in the EMA region. He can be contacted on +27 21 408 7022 or by email: firstname.lastname@example.org.
Robert Driman is a director at Norton Rose. He is a commercial lawyer specialising in commercial and banking and finance and his experience makes him uniquely placed to advise corporate clients on virtually any aspect of their business – in particular high-profile complex commercial and regulatory issues. Mr Driman has gained considerable experience in advising listed and non-listed South African and international corporate clients in banking and financial services and insolvency, industry and manufacturing and consumer and luxury goods. He can be contacted on +27 21 405 1310 or by email: email@example.com.
© Financier Worldwide
Reagan R. Demas
Baker & McKenzie LLP