News & Analysis as of

Building Your Third Party Due Diligence Checklist: The Right Pieces, Processes and Presumptions

A comprehensive approach to third party and vendor due diligence management is essential for any company conducting business globally. A strong due diligence program’s purpose is two-fold...more

17 Red Flags for Potential International-Sanctions Violations

Recent events in Ukraine and the Middle East have expanded sanctions placed by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) against certain foreign financial institutions and individuals. This...more

Analysis of Recent Trends in Warranty Insurance in Private Equity M&A Transactions

Although Warranty Insurance in M&A transactions was a novelty product five to ten years ago, Warranty Insurance has now become an industry standard in Europe, largely thanks to its wide use by private equity firms who have...more

Overview of Recent Trends in Warranty Insurance in M&A Transactions

In the current economic climate, the appetite of purchasing parties to take on risk in an M&A transaction has greatly decreased. At the same time, sellers remain under intense pressure to contain outstanding liabilities, and...more

Higher Education Risk Management Conference: Establishing International Programs: Risks and Due Diligence

Globalization: -- Reshaping the world in the past several decades: .. continued growth of multinationals .. increased cross-border workers and consumers .. increased imported goods and services --...more

SEC Staff Offers Roadmap for Alternative Investment Due Diligence Processes

The SEC believes that investment advisers, including pension consultants, are increasingly recommending that their clients invest a portion of their portfolios in private alternative investment funds. In light of that trend,...more

FFIEC Social Media Guidance Addresses "Reputational Risks" from Social Media

Financial Institutions Should Develop Policies and Practices to Address and Monitor Reputational and Operational Risks - On December 10, 2013, the Federal Financial Institutions Examination Council (FFIEC) issued its...more

FRB Issues Guidance on Managing Third Party Service Providers Risks

The FRB issued guidance on managing outsourcing risks, intended to highlight the potential risks arising from the use of service providers, describe the components of an appropriate service provider risk management program,...more

Special Alert: Federal Reserve Board Guidance On Managing Outsourcing Risks Mirrors Recent OCC Guidance

On December 5, 2013, the Federal Reserve Board (FRB or the Fed) issued Supervision and Regulation Letter 13-19, which details and attaches the Fed’s Guidance on Managing Outsourcing Risk (FRB Guidance). The FRB Guidance...more

FINRA gives member firms a thumbs up on suitability rule compliance

Abstract: Purpose – The purpose of this paper is to interpret Financial Industry Regulatory Authority (FINRA) Regulatory Notice 13-31, which provides practical advice to member firms about how FINRA will be...more

OCC Issues New Third-Party Risk Management Guidance

On October 30, 2013, the Office of the Comptroller of the Currency (OCC) issued new guidance on risks presented by third-party relationships, entitled “Third-Party Relationships: Risk Management Guidance” (“2013 Bulletin”)....more

OCC Releases New Third Party Guidance

On October 30, 2013, the OCC published a broad update of its guidance regarding national banks and their third-party relationships. The guidance also applies to federal savings associations (“FSAs”) as well as extending...more

OCC Releases Guidance on Third-Party Relationships

The OCC issued guidance to national banks and federal savings associations in assessing and managing risks related to third-party relationships. The OCC defines a third-party relationship as “any business arrangement between...more

Special Alert: OCC Updates Third-Party Risk Management Guidance

On October 30, the OCC issued Bulletin 2013-29 to update guidance relating to third-party risk management. The Bulletin, which rescinds OCC Bulletin 2001-47 and OCC Advisory Letter 2000-9, requires banks and federal savings...more

Third Party Risk in a Global Environment

Most organizations engage with hundreds, if not often thousands, of third party vendors, suppliers, agents and business partners, creating a daunting and ever-expanding scope of risk. This risk arises from: 1....more

Bribery, Corruption, and Third Party Risks - What Can You Do.

Please see full Infographic below for more information....more

A Prescriptive Guide To Third Party Risk Management

The recent examples of compliance program credits for Morgan Stanley and Ralph Lauren have demonstrated that, more than ever, an effective compliance program can protect a company from criminal indictment and generate bottom...more

Companies Turning to Technology to Combat Third Party Risk

As technology continues to increase the efficiency of most operational tasks, it should come as little surprise that technology can now improve the labor-intensive process of managing third party risk. The days of manual...more

Managing And Minimizing Your Third-Party Risks

Let’s start with a few basic assumptions – we all know that third parties are often the most significant risk for corruption. ...more

Why Ignorance Isn’t Bliss When It Comes to Third Party Risk Management

In a recent webinar, Randy Stephens, VP of our Ethical Leadership Group, and Mike Vermilion, Senior Director of Third Party Risk Solutions, outlined a best practice approach to risk-adjusted due diligence for third party...more

From The Compact Model To The Luxury Model – Managing Your Third Party Risk

I am currently attending the Hanson Wade Oil and Gas Supply Chain Compliance conference in Houston. The event is excellent and the presentations have been ‘spot on’ for the nuts and bolts of how to do compliance. As the...more

Anti-Corruption High-Risk Audits

The Justice Department and the SEC should be credited with promoting new compliance strategies and best practices. Whatever you may think about the DOJ/SEC FCPA enforcement program, they have pushed businesses to enhance...more

EPA Clarifies "Innocent Tenant" Liability Under CERCLA

Recent EPA guidance imposes new environmental due diligence and compliance requirements on prospective commercial and industrial tenants. The guidance purports to clarify an exemption from liability, but actually confirms...more

Third Party Risks And Internal Auditors

You remember the corny song – “People who need people are the luckiest people in the world.” For a Chief Compliance Officer that saying is particularly important when it comes to third party risks. CCOs need their...more

Antimonopoly Law Considerations and Risk Management in connection with M&A Transactions

In This Presentation: - General Indemnity: (1) Background and structure (2) Main provisions (3) Conduct of claims - Antitrust Indemnity: (1) Background (2) Main provisions (3) Conduct of...more

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