Third-Party Risk

News & Analysis as of

Vendor Management Risks and Controls

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

Implementing an Effective Third Party “Audit” Program

Explore new approaches to third party audits for a more effective, risk-aligned third party risk management program.    Compliance officers have been insisting on (and should continue to insist on) including third party...more

New York’s DFS Reports on Third-Party Cyber Security

Why it matters - A new report released by New York’s Department of Financial Services (DFS) detailed the vulnerabilities found in the relationships that many financial institutions have with their third-party vendors....more

New York Regulator Finds Substantial Cyber Vulnerabilities in Banking System

Earlier this month, Benjamin Lawsky, Superintendent of Financial Services for the New York State Department of Financial Services (NYDFS), released a report finding “significant potential” vulnerabilities for cyber theft of...more

Keeping It Classified: Here’s How To Stay Safe In A Technology-Driven World.

Protecting a company’s confidential information is becoming more difficult as technology continues to advance. Plus, an increasingly mobile workforce poses increased risk that employees will breach a company’s security...more

NY Department of Financial Services: Check Your Vendors’ Cybersecurity

According to a recent report released by the New York Department of Financial Services (NYDFS), the financial industry has a long way to go in overseeing the cybersecurity capabilities of outside vendors who carry out...more

Customer Liability Under The Minimum Wage Act: Recommendations For Reducing Liability Risks

Since the start of the year, companies have been grappling with letters from their clients (customers), in which these customers are demanding compliance with the Minimum Wage Act (MiLoG), referencing their own potential...more

New York Department Of Financial Services Says Banks’ Security Oversight Of Vendors Is Inadequate

On April 9, 2015, the New York Department of Financial Services (“NYDFS”) issued a report entitled Update on Data Security in the Banking Sector: Third Party Service Providers (the “Report”). The Report details findings of a...more

Labor Contractors Can Make Dangerous Bedfellows: Part I

According to many sources, there is a shortage of unskilled workers in the United States that is only projected to worsen, and employers nationwide are feeling the pinch. From hoteliers to seafood processors, manufacturers to...more

A Warning to 401(k) Plan Sponsors Relying on Third-Party Administrators (TPAs)

A recent news bulletin from the IRS serves as a cautionary reminder that plan sponsors retain responsibility for the proper administration of participant hardship distributions and loans, and related recordkeeping...more

NYDFS Cyber Security Report Shows Vulnerabilities in Banks’ Third-Party Vendors

On April 9, the NYDFS released a report finding potential cyber security vulnerabilities with banks’ third-party vendors, based on a survey of 40 banking organizations regarding the cyber security standards in place for their...more

Report Highlights Bank Vendor Cybersecurity Vulnerabilities

On April 9, the New York State Department of Financial Services (NYDFS) released a report on bank vendor cybersecurity that highlights the risk that hackers will use third-party service providers to gain access to bank data....more

Bridging the Week - April 2015 #2

IOSCO Seeks Views on Business Continuity and Recovery Planning by Trading Venues and Intermediaries; NYS Warns on Third-Party Service Providers - The International Organization of Securities Commissions issued two...more

Five Big IP Considerations for Growing Businesses

Entrepreneurs starting their businesses often follow a well-beaten path to get their companies off the ground, balancing the need to keep legal costs low against the necessity of some initial investment. ...more

Regulatory Blue Pencil: CFPB Guidance, Enforcement Actions Signal Expanding Focus on Vendor Management

In April 2012, the Consumer Protection Financial Bureau (the ‘‘CFPB’’ or ‘‘Bureau’’) issued Bulletin 2012-03 (the ‘‘Service Provider Bulletin’’), a guidance document setting forth the CFPB’s high-level expectations related to...more

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

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

Managing Your Third Parties in a FCPA Compliance Program

The building blocks of any Foreign Corrupt Practices Act (FCPA) anti-corruption compliance program lay the foundations for a best practices compliance program. For instance in the lifecycle management of third parties, most...more

Supply Chain as a Source of Compliance Innovation

On this day we celebrate the greatest upset in the history of the NCAA Basketball Tournament, when Villanova beat Georgetown for the 1985 national championship. Georgetown was the defending national champion and had beaten...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

Technology is Transforming Third Party Risk Management: Predicting the Future

I usually avoid predicting the future because I am often wrong. But in this case I’m going to make an exception. Here is my 100 percent, sure-to-be true prediction: technology is going to change how compliance professionals...more

Top Ten Ethics & Compliance Predictions and Recommendations for 2015

Get the inside track on the key ethics and compliance industry trends that will impact your business in 2015—and get the resources you need to help you plan for the year ahead—in our annual Top Ten Predictions and...more

Managing Risks in Vendor Relationships

For years, banks have relied on third party vendors to provide specialized products or services, or have used outsourcing as a way to reduce internal operating costs. In the wake of the financial crisis, however, regulators...more

Third Party Audits: Biting the Bullet

The next compliance frontier in anti-corruption enforcement is third-party audits. We have spent the last few years fashioning third-party audit contractual provisions to define when and how such audits can be conducted. ...more

Managing Retail Employer Risk and the Janitorial Services Contractor-Subcontractor Relationship

Discount retailer Ross Stores, Inc.'s ("Ross") recent proposed settlement of a California labor law class action filed by immigrant and low wage subcontractors related to janitorial services performed in its Ross Dress for...more

Making the Case for Compliance Training for Third Parties

How to make the case for implementing third party compliance training in your organization. A recent article in the San Francisco Chronicle profiled Jay Jorgensen, the new Global Chief of Compliance at Walmart. The...more

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