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FCPA Compliance and Ethics Report-Episode 157-Training of Third Parties Under the FCPA
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FCPA Compliance and Ethics Report-Episode 91, Internal Controls for Third Parties Under the FCPA, Part II
FCPA Compliance and Ethics Report-Episode 63-Managing the Third Party Relationship Under the FCPA, Part I
Financial technology companies (fintechs) and other third parties in bank partnerships are routinely subject to scrutiny by their banking partner customers. The Federal Reserve System, the Federal Deposit Insurance...more
Often parties to a contract will agree that a third party will make the final call as to whether an obligation has been performed or an amount to be determined post-closing. In California, it has long been held that the...more
On July 13, the Federal Reserve, FDIC, and OCC proposed risk management guidance to help banking organizations manage risks related to third-party relationships, including relationships with vendors, FinTech companies,...more
On October 20, 2017, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2017-43 (the “Bulletin”) outlining principles that OCC-supervised banks should follow to prudently manage the risks associated with...more
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
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