News & Analysis as of

Third-Party Relationships Compliance

Procurement Pressure: The Convergence Of Supply And Compliance

by Thomas Fox on

With a growing number of complex regulations and directives, the only thing that is constant right now in the regulatory environment is change. Supply chain leaders and compliance professionals alike continue to grapple with...more

The Challenge of Auditing and Monitoring Your Distributors

by Michael Volkov on

Whether you are in the high-tech industry and managing your channel partners (i.e. third-party distribution network), the pharmaceutical and medical device industry managing a complex network of distributors and...more

Termination of a Third-Party – Planning Can Reduce the Pain

by Thomas Fox on

The European concern Airbus has been in the news recently for corruption issues. According to an article in the Financial Times (FT), entitled “Airbus sued by middlemen fired following fraud inquiry”, its annual report lists...more

Justice Department Reveals How It Evaluates Corporate Compliance Programs

by Holland & Knight LLP on

The U.S. Department of Justice (DOJ) Fraud Section recently published its "Evaluation of Corporate Compliance Programs" that lists 1) the topics it explores and 2) the questions it asks when it assesses the effectiveness of a...more

Deep Dive Due Diligence: Part IV – Level III Due Diligence for 3rd Parties

by Thomas Fox on

Today, I continue my exploration of Level III, deep dive due diligence, by discussing how this should be considered for third parties. I am joined this week by Candice Tal, founder and Chief Executive Officer (CEO) of...more

The DOJ Expects “Third-Party Management” from Compliance Programs

2016 was a banner year for global anti-corruption enforcement: the U.S. government set records in terms of both the number of FCPA actions brought and the total dollar amount of related fines. Meanwhile, governments from...more

Department of Justice Fraud Section Provides Guidance on Evaluating Corporate Compliance Programs

by Jones Day on

On February 8, 2017, the United States Department of Justice ("DOJ") Fraud Section published a blueprint for assessing corporate compliance efforts, titled "Evaluation of Corporate Compliance Programs" ("Guidance"). It...more

Group-Level Accountability for Third-Party Risk: Why It’s So Hard

by NAVEX Global on

Of the wide range of challenges that compliance officers face with third parties, my favorite is: who “owns” third-party risk management? The truth is that different people within the enterprise feel different types of pain...more

Coordinating Third Party Due Diligence and Procurement

by Michael Volkov on

Third party risk management is easily one of the most challenging risks for compliance officers. With all the attention and hype surrounding third party risk, companies have marshaled attention and resources to mitigate the...more

On Leadership – A Simple Message and Asking the Right Questions

by Thomas Fox on

Sometimes, as a leader it is important to say something numerous times, to repeat your message so that it will come through loud and clear. For any Chief Executive Officer (CEO) it is incumbent to continually reinforce your...more

When Lawyers Cross the Line – Breaking Bad Under the Law

by Michael Volkov on

While reading the Embraer settlement documents, I read over the facts implicating a senior legal executive and his/her involvement in the Embraer bribery scheme. Truthfully, I had a slight gasp as I read about a fellow lawyer...more

Good-Bye to Wyatt Earp and More on 1MDB

by Thomas Fox on

Wyatt Earp died this week. Not the original Wyatt Earp who died in 1929 but the Wyatt Earp of my lifetime, who was actor Hugh O’Brian. O’Brien portrayed Earp in the long running television series Wyatt Earp which ran in the...more

Hallmark 7-Third-Party Due Diligence and Payments

by Thomas Fox on

There are five steps in the life cycle of third party management. - Business Justification and Business Sponsor; - Questionnaire to Third Party; - Due Diligence on Third Party; - Compliance...more

Hallmark 2 – Code of Conduct and Compliance Policies and Procedures

by Thomas Fox on

The cornerstone of a Foreign Corrupt Practices Act (FCPA) compliance program is its written protocols. This includes a Code of Conduct, policies and procedures. In the FCPA Guidance, the Department of Justice (DOJ) and...more

Third Party Risk Management: Balancing Due Diligence Screening and Monitoring

by Michael Volkov on

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

Data Analytics Week – Part IV: Third Parties and Duplicate Invoices

by Thomas Fox on

I continue my exploration of the use of data analytics in a best practices compliance program. Today we look at how data analytics can be used to help detect or prevent bribery and corruption where the primary sales force...more

Common FCPA Issues

by Foley & Lardner LLP on

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

Due Diligence and Risk Priorities (Part III of IV)

by Michael Volkov on

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

FCPA Compliance and Ethics Report-Episode 157-Training of Third Parties Under the FCPA

by Thomas Fox on

In this episode I discuss the training of third parties under the FCPA. I review the DOJ/SEC FCPA Guidance on this issue; the risk ranking of third parties to help deliver your training; the types of training you can utilize...more

Technology is Transforming Third Party Risk Management: Predicting the Future

by NAVEX Global on

The definition of “effectiveness” for a third party risk management program is quickly changing — how is your organization keeping up? I usually avoid predicting the future because you are bound to get something wrong. ...more

Insurance Review (Australia) - February 2015

by DLA Piper on

In This Issue: - REGULATORY: - The Financial System Inquiry - Insurance Reform In The UK - CYBER: - Top Five Privacy And Cyber Predictions, Trends And Issues Impacting Insurers In 2015 And...more

FCPA Compliance and Ethics Report-Episode 91, Internal Controls for Third Parties Under the FCPA, Part II

by Thomas Fox on

In this episode, I continue my exploration of internal controls around third parties in a FCPA compliance program, with Henry Mixon. ...more

Internal Controls for Third Party Representatives in a FCPA Compliance Program

by Thomas Fox on

This week, I am continuing my podcast series, on the FCPA Compliance and Ethics Report, on internal controls in best practices anti-corruption compliance program, under the Foreign Corrupt Practices (FCPA), UK Bribery Act or...more

What Can You Do When Risk Changes in a Third Party Relationship?

by Thomas Fox on

The GlaxoSmithKline PLC (GSK) corruption matter in China continues to reverberate throughout the international business community, inside and outside China. The more I think about the related trial of Peter Humphrey and his...more

Thinking Through Risk Rankings of Third Parties

by Thomas Fox on

One question often posed to me is how to think through some of the relationships a company has with its various third parties in order to reasonably risk rank them. Initially I would break this down into sales and supply...more

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