Subro Sense - The ABC's of RCV and ACV
Episode 120: Interview of NAVEX Global Third-Party Risk Officials: Chris Bailey and Stephen Gooding
Homebuilder Series Webinar: Fiduciary Duties & Auditor Liability
The New Normal: Taking Responsibility for Your Vendors
Most discussions of why third party due diligence is so important begin with an explanation of indirect liability and the “deliberate ignorance” standard of knowledge the FCPA imposes. With so much focus on anti-bribery it is...more
With all of the privacy and data security enforcement actions brought by the Federal Trade Commission in recent years, and with all of the guidance distributed by the FTC in that time frame, it is easy to get caught up in...more
On January 29, the U.S. Government released a final rule establishing new anti-human trafficking requirements for U.S. government contractors. The rule amends the Federal Acquisition Regulation (“FAR”) and seeks to strengthen...more
Traditionally, performing third party due diligence has been primarily a data gathering activity. Now, with access to abundant information sources, the activity—and the challenges—have evolved. How do you manage and...more
Compliance officers face lots of challenges when conducting third-party due diligence. One issue that frequently arises is determining who exactly owns a potential agent or distributor. ...more
Let’s start with a few basic assumptions – we all know that third parties are often the most significant risk for corruption. ...more
Recent action by the Federal Trade Commission against a third party processor found to be processing transactions for a merchant engaged in wrong-doing, indicates the necessity of processors employing adequate due diligence...more
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