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Third-Party Relationships Third-Party Risk

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

Trust But Verify - Due Diligence with a Jaded Eye

by Michael Volkov on

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

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

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

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

Vendor Management Risks and Controls

by Poyner Spruill LLP on

What are the Risks? In an effort to heighten efficiency and cost effectiveness, many financial institutions choose to outsource certain services to third party vendors. While these providers often play a beneficial...more

Why Tone at the Top Matters and Join the FCPA Professor in Houston

by Thomas Fox on

Over this week I have looked at some issues related to compensation and methods from other disciplines that a compliance practitioner might use to test and then improve a company’s third party management regime. Today, I want...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

Four’s A Crowd: Third-Party Bad Faith Cases Test the Limits of the Tripartite Relationship

by Carlton Fields on

A significant minority of states permit plaintiffs who win judgments against insured defendants to assert claims directly against the defendants’ insurers—including claims for extracontractual liability, based on alleged bad...more

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

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

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

Insurer Claims Attorney-Client Privilege Of Third Parties Prohibits Disclosure To Its Own Attorneys

by Allen Matkins on

At first, this case seems somewhat pedestrian – a lawyer sues her erstwhile law firm for employment discrimination. But then things get complicated. It turns out that the lawyer was employed by a law firm that was employed...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

Life Cycle Management Of Third Parties – Step 4 – The Contract

by Thomas Fox on

This post continues to outline what I believe are the five steps in the life cycle of third party management. Today I will look at Step 4, the contract. However, before we get to the contracting stage a word about what to do...more

Nixon Goes To China And Management Of Third Party Relationships

by Thomas Fox on

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

OCC Issues New Risk Management Guidance For Third Party Relationships

The Office of the Comptroller of the Currency published on October 30, 2013 a new Guidance relating to risk management for third party relationships. This Guidance rescinds OCC Bulletin 2001-47, “Third-Party Relationships:...more

OCC Issues Updated Risk Management Guidance Concerning Third-Party Relationships

by Goodwin on

The OCC issued updated and comprehensive guidance (OCC Bulletin 2013-29, the “Guidance”) to national banks and federal savings associations (collectively, “Banks”) concerning assessment and management of risks associated with...more

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