(Sill, Inc.

The manual’s anti-corruption and compliance guidance supports a risk-based due diligence approach for business relationships involving elevated corruption exposure. It explains that organizations should apply appropriate due diligence and compliance requirements for third parties and business partners, and that anti-corruption programs should be designed based on assessed risk. In a transaction involving a new foreign customer from a high-corruption-risk country and an unusually large order, the company should not treat the transaction as routine or ignore red flags. Instead, it should evaluate whether the transaction fits the customer’s expected purchasing behavior and whether the payment method is consistent with a legitimate commercial relationship. Those factors help determine whether the deal presents heightened fraud, bribery, or money-laundering concerns. Therefore, the most accurate answer is that Sill should consider A & P’s expected purchasing pattern and method of payment before proceeding.