Due Diligence Compliance

News & Analysis as of

The Only Thing You Have to Fear . . . Is No Documentation

Compliance is a profession that requires multi-tasking – another profound grasp of the obvious. But in the multi-tasking world, some principles and strategies are more important than others. My colleague and compliance...more

[Webinar] How do I Demonstrate the Advantages of an Automated Third Party Due Diligence System to Senior Leadership? - July 8th,...

Join NAVEX Global and a group of your peers for a short session where we’ll answer your questions and share solutions about third party due diligence and risk management software....more

Third Party Risk Management: Balancing Due Diligence Screening and Monitoring

In response to aggressive FCPA enforcement and recurring problems with third parties, companies have spent substantial resources and time to design and implement comprehensive ethics and compliance programs. A key part of...more

The Panama Papers and Shell Games, Part I

One of the more prescient authors I know is Ryan C. Hubbs, a senior manager of fraud investigation and dispute services at Ernst & Young LLP (EY), who, in 2014, wrote an article for Fraud Magazine entitled “Shell Games”. In...more

The SEC, CCOs and Compliance Programs

Compliance programs, Chief Compliance Officers and liability have been the subject of a great deal of debate in recent months. Members of the Commission, for example, debated charging decisions regarding CCOs last year in...more

Corruption Risks and Corporate Social Responsibility Spending

Global companies have been embracing socially responsible spending projects to build stronger relationships with local communities. The idea makes a lot of sense and real projects can result in real benefits....more

Panama Papers Scandal Puts Third Party Risk in Focus

The Panama Papers scandal should serve as a wake-up call for every organization—and it should prompt compliance officers to closely scrutinize the third party vendors they do business with. ...more

Checking In on “The Year of Third-Party Due Diligence”

Hui Chen, the Department of Justice’s Compliance Counsel, recently stated that 2015 was the year of due diligence and third-party compliance. A recent survey conducted by Kroll and Ethisphere provided a status check on how...more

Key Findings from NAVEX Global's Third Party Risk Management Benchmark Report

Vendor risk management and, in particular, third party risk management has become one of the toughest issues companies face—especially after a string of high-profile compliance failures in recent years. The majority of...more

Olympus Settles FCPA Charges with DOJ

The Department of Justice resolved another FCPA investigation centered on payments made to health officials. Olympus Corporation of the Americas, a wholly owned subsidiary of Olympus Corporation, Tokyo, Japan, and Olympus...more

2015 Ethics & Compliance Third Party Risk Management Benchmark Report

Organizations are still coming to terms with the breadth and depth of their third party risk. An effective third party risk management program is in the interest of all organization —regardless of their size, industry, and...more

Due Diligence and Beyond — Balancing Competing Priorities

DOJ’s compliance counsel, Hui Chen, pronounced this year as the compliance year of third party due diligence. This has been a good year for compliance but I would not characterize this year as limited to third party due...more

China Doll and FCPA Risk in the Supply Chain

I was recently in New York and was able to see the theater production of the new David Mamet play China Doll. It stars Al Pacino and it is probably worth it simply to see Pacino on stage. As you might expect from any Mamet...more

Corruption and the Closing Table: How Much Diligence is Due?

It is 2016 (almost). We all have heard about corruption – outrageous tales of money changing hands to enable access to new markets in under-regulated parts of the world, or payments for access to foreign ports, expediting the...more

Win-Wins: Looking for Business and Compliance Success

A Chief Compliance Officer who lacks working relationships with the business side of a company is like a day without sunshine. No matter how strong or finely tuned a compliance program is on paper – in practice, the success...more

Private equity firms: In the line of antitrust fire?

There was a time when private equity firms may have seen themselves as arms-length financial investors but regulators are increasingly holding them responsible for the behaviour of their portfolio companies. A new type...more

The Modern Slavery Act 2015: Transparency Reporting Provisions

What do the new UK transparency reporting provisions mean for companies? The UK is at the forefront of the global move to tackle human trafficking and prevent modern forms of slavery by introducing the Modern Slavery Act...more

Upcoming Abandoned Property Deadlines

Just a friendly reminder that the first deadline for New York’s annual abandoned property due diligence mailings is quickly approaching. Here’s a quick recap of the deadlines and the rules governing New York’s abandoned...more

FinCEN Proposes Anti-Money Laundering and Suspicious Reporting Rules for Registered Investment Advisers

On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more

Common FCPA Issues

As our previous posts illustrate, violations of the Foreign Corrupt Practices Act (“FCPA”) can carry a hefty cost. Two issues are commonly the impetus for FCPA violations and, practically speaking, pose significant FCPA...more

Australian Anti-Bribery & Compliance Trends

Today we welcome Ted Williams, Partner, Piper Alderman. Ted, can you share some of your background and experience? TW: Thank you, Richard, for the opportunity to engage with your community, and it was a pleasure to...more

Allocation, Due Diligence, and More Record Keeping! New Draft Regulations on New York State’s Corporate Income Tax Allocation

2014 brought significant corporate income tax reform to New York State. This year, 2015, followed suit and brought many of those same corporate income tax reforms to New York City. To quote Donald Trump, these reforms are...more

Modern Slavery Act: How to Comply with the ‘Corporate Provision’

On 29 October 2015, the ‘corporate provision’, section 54, of the Modern Slavery Act (the “Act”), came into force. All businesses in the UK with a global turnover of £36 million will now be required to publish an annual...more

Building a Due Diligence Infrastructure (Part IV of IV)

A due diligence infrastructure is designed to demonstrate a company’s good faith commitment to compliance with anti-corruption laws by: identifying corruption risks; and mitigating such risks to ensure that the company does...more

Due Diligence and Risk Priorities (Part III of IV)

Believe it or not, life principles can be used in compliance, especially in due diligence. I always tell my kids that life has a way of setting priorities. As you get older, life becomes simpler and your priorities become...more

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