In my last corporate position, my company was at the cutting edge because we required compliance related audits for vendors in the supply chain. This was cutting edge in 2007-08. However, now an audit for adherence to compliance requirements has become a standard best practice in the management of business relationships with third party vendors which work with a company through the supply chain. In several settlements of enforcement actions through both Deferred Prosecution Agreements (DPA) and Non-Prosecution Agreements (NPA), in See more +
In my last corporate position, my company was at the cutting edge because we required compliance related audits for vendors in the supply chain. This was cutting edge in 2007-08. However, now an audit for adherence to compliance requirements has become a standard best practice in the management of business relationships with third party vendors which work with a company through the supply chain. In several settlements of enforcement actions through both Deferred Prosecution Agreements (DPA) and Non-Prosecution Agreements (NPA), in the 2012 FCPA Guidance, the Department of Justice (DOJ) and most recently in the Evaluation of Corporate Compliance Programs; made it clear that a best practices FCPA compliance program includes the right to conduct audits of the books and records of its suppliers to ensure compliance. Many companies have yet to begin their audit process for FCPA compliance on vendors in their supply chain. I find this to be a missed opportunity from both the compliance perspective and greater business efficiency.
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