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Thinking Through Risk Rankings of Third Parties

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

Termination of a Third Party or Breaking Up Should Not Be Hard To Do

One of treats each month for the compliance professional is reading the GRC Illustrated column by Carole Switzer, President of the Open Compliance and Ethics Group (OCEG), in the Compliance Week magazine. Not only does...more

FCPA Compliance and Ethics Report-Episode 63-Managing the Third Party Relationship Under the FCPA, Part I [Video]

In this episode I being a two part series on how to manage your third party relationships under the FPCA and UK Bribery Act. In this episode, steps 1-the Business Justification and Step 2-the Questionnaire. ...more

The Mann Gulch Fire and How Far Down the Chain Do You Need to Go?

Robert Sallee died last week. A smoke jumper, he was the last survivor of the Mann Gulch Fire, one of the worst disasters in the history of the US Forest Service. Sallee’s story and that of the Mann Gulch Fire was detailed in...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

Life Cycle Management Of Third Parties – Step 5 – Management Of The Relationship

Today ends my review of what I believe to be the five steps in the management of a third party under an anti-bribery regime such as the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act. On Monday, I reviewed Step 1 –...more

Life Cycle Of Third Party Management – Step 1 Business Justification

With thanks to the Two Tough Cookies, I am back from a successful Spring Break college tour to universities in the state of Washington. My daughter and I had a great time, experienced some typical and untypical Seattle...more

Nixon Goes To China And Management Of Third Party Relationships

Today we honor one of the greatest diplomatic initiatives that occurred in my lifetime, Nixon’s trip to China; where he arrived on this date in 1972. Like most Americans I was caught completely unaware that Nixon was planning...more

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