An article in the September, 2011 issue of Compliance Week, entitled, “How Tyco Turned Around Third-Party Risk Program” by author Karen Kroll, reported on the program initiated and developed by Tyco International, assisted by Navigant Consulting, to enable Tyco to develop and initiate a “comprehensive program to gain a better control over the activities of third parties.” This task seemed particularly daunting as Tyco initially identified over 66,000+ third party vendors and this group needed to be risk assessed to determine the high risk third parties which could be handled in the first pass.