Third-Party Relationships Due Diligence

News & Analysis as of

The Fall of Big Sam

Last week, the Football Association (FA) dispensed with the services of its shortest-serving England manager after just 67 days in the role and following only one game in charge. Sam Allardyce (Allardyce) was removed from his...more

Trust But Verify - Due Diligence with a Jaded Eye

Ronald Reagan’s mantra with respect to US-Soviet relations in the 1980s applies with equal force to today’s world of due diligence. (I know it shows my age that I can recall this statement). Not all due diligence cases...more

Hallmark 7-Third-Party Due Diligence and Payments

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

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

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 How Question in Due Diligence

What is satisfactory due diligence under the Foreign Corrupt Practices Act (FCPA)? That question seems to be more important after the Huffington Post’s story on Unaoil and the subsequent release of the Panama Papers. However,...more

The Evolving Due Diligence Standards and Beneficial Ownership

In case you are not following all the latest scandals – Unaoil and the Panama Papers being two significant ones – we are seeing an evolution and possibly a revolution in due diligence expectations....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

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

The Missing Link in Third Party Due Diligence

It is one thing to screen a third-party at the on boarding process; it is quite another to build out an entire due diligence system that screens at renewal of a third-party relationship, monitors third-party activity and...more

Questioning Due Diligence Questionnaires — Keeping It Simple

Third Party questionnaires are a standard part of any due diligence process. They are emailed to the potential third-party business partner, filled out and sent back, or the third-party enters the information through an...more

Technology is Transforming Third Party Risk Management: Predicting the Future

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

Third Parties and the Red Flags You Don’t See

Recently, I was reading a White Paper by Dun and Bradstreet titled “Anti-Bribery and Corruption Compliance for Third Parties: Is an off the shelf product enough?”. As the D&B paper points out, “the risks of insufficient...more

Working With Third Parties In The Due Diligence Process

On this day we celebrate the 1607 founding of the English colony at Jamestown. While credited with being the first English colony in what became America, it’s probably more accurate to refer to it as the first permanent...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

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