Third-Party Risk

News & Analysis as of

What GCs Need to Know About HR Technology

Imagine that your General Counsel asks you for a very brief overview of what she needs to know - and worry about - related to HR technology and HR data management. If your GC is like most we know, she has way too much on her...more

WEBINAR: Cloud Computing & Health Care Organizations - Critical Privacy & Security Issues

More and more organizations are turning to the cloud because of how flexible and low-cost it is. As a result, many health care organizations are now using cloud-based servers to store patient information and are discovering...more

U.K. Procurement Managers to Vendors: Take Cyber Security Seriously or You’re Out

The headlines about massive cyber-security breaches just keep coming these days. Corporate giants Vodaphone, Home Depot, Talk Talk and JP Morgan Chase have all been hacked—to and they're far from the only ones.. But the...more

Third Party Service Providers Remain in the Spotlight

Yesterday, the Office of the Comptroller of the Currency (OCC) released its Semiannual Risk Perspective (the “Semiannual Risk Perspective”). The Semiannual Risk Perspective covers “key issues facing banks, focusing on those...more

When A Customer Harasses Your Employee – What Should You Do?

As an employer, what do you do when one of your employees reports being sexually harassed by a vendor? Easy, right? You call the vendor’s boss and say, “If you want to continue doing business with us, then you will not...more

Advisory on Effective Risk Management Practices for Purchased Loans and Purchased Loan Participations

On November 6, 2015, the Federal Deposit Insurance Corporation issued an Advisory (the “Updated Advisory”) (FIL-49-2-15) to update information contained in the FDIC Advisory on Effective Credit Risk Management Practices for...more

Privacy & Data Security Advisory: It’s Not Just Europe: Why 2016 Cloud Vendor Management Programs Should Address Evolving Global...

2015 has seen landmark changes in privacy and cybersecurity laws and regulatory best practices. These developments have had a direct impact on cloud vendors. For example, evolving judicial and regulatory interpretations of...more

Purchased Loans From Alternative Lenders Should Be Accorded the Same Risk Analysis as Originated Loans, FDIC Reminds Banks

Why it matters - In a new advisory, the Federal Deposit Insurance Corporation (FDIC) provided a reminder to all covered entities of the importance of underwriting and administering purchased loans and loan participations...more

Due Diligence and Beyond — Balancing Competing Priorities

DOJ’s compliance counsel, Hui Chen, pronounced this year as the compliance year of third party due diligence. This has been a good year for compliance but I would not characterize this year as limited to third party due...more

Interview: Third Party Risk Management on the Front-Line

In an interview with Leas Bachatene, CEO at ethiXbase, Richard Bistrong, CEO at Front-Line Anti-Bribery LLC, shares his views on front-line third party risk management in today’s business environment. Originally...more

Delaware Supreme Court Decision in Rural/Metro Affirms $76 million Judgment Against Third-Party Advisor for Aiding and Abetting...

On November 30, 2015, the Delaware Supreme Court affirmed post-trial decisions by the Delaware Court of Chancery (i) holding RBC Capital Markets, LLC liable to Rural/Metro Corp. shareholders for nearly $76 million based upon...more

New York DFS Proposals Focus on Third-Party Vendor Risk

Earlier this month, the New York State Department of Financial Services (“DFS”) announced that it will propose new cybersecurity regulations for financial institutions. The DFS made the announcement in a letter to the...more

Don’t Lose a No-Hitter – Use of Questionnaire and Compliance Terms and Conditions

Before Jim Crane came along to purchase the Houston Astros and provide us all with some of the best lessons learned for the compliance practitioner, they had a long and storied history, even if part of that history included...more

Investment Firms and Compliance Professionals Beware: SEC Finds Risks Associated with Outsourcing Compliance Function

On Monday, November 9, 2015, the Office of Compliance Inspections and Examinations (“OCIE”) of the U.S. Securities and Exchange Commission (“SEC”) released results from its evaluation of investment adviser firms’ use of third...more

Compliance Counsel Metrics – Part IV: Third Party Management

Today, I conclude my exploration of the new Department of Justice (DOJ) Compliance Counsel and the metrics laid out by Assistant Attorney General Leslie R. Caldwell who called for her review of compliance programs. The...more

Preview of NAVEX Global’s 2015 Ethics and Compliance Virtual Conference

As 2015 draws to a close (where did the time go?), the 2016 planning season is in full swing. You likely already have an idea of initiatives you’ll want to tackle, but taking your ethics and compliance program to the next...more

Building a Due Diligence Infrastructure (Part IV of IV)

A due diligence infrastructure is designed to demonstrate a company’s good faith commitment to compliance with anti-corruption laws by: identifying corruption risks; and mitigating such risks to ensure that the company does...more

Waste on land: a warning for landowners

Fly-tipping continues to cause problems for businesses, governments and communities. Defra recently assessed the number of fly-tipping incidents during 2014-2015 at around 900,000 in England alone.1 It comes as a surprise to...more

A Holistic Approach to Third-Party Risk & Due Diligence

The following interview is with Leas Bachatene, CEO at ethiXbase. Hi Leas, thank you for participating in today’s Q and A. I have really enjoyed working with the ethiXbase team, including on our recent White Paper and...more

New Study Highlights Anti-Bribery & Corruption Gaps & Risks

Everyone reading this post should have conducted a corporate risk assessment (CRA) in the past couple years. If not, stop reading and go conduct one now. Seriously, how can you know if your compliance program resources,...more

New Opportunities in Cross-Border Special Situations Lending

Recent changes in cross-border leveraged loan documentation requirements open up new possibilities for both borrowers and lenders. Cross-border leveraged loan documentation has become increasingly permissive with respect...more

Companies: Five Steps to Protecting Trade Secrets

If your management team knows it needs to better protect company trade secrets but isn’t sure where to start, take note. CREATe.org and PwC have put together a five-step framework to guide companies on how to identify, assess...more

The SEC OCIE Announces Increased Scrutiny of Broker-Dealers’ and Investment Advisers’ Cybersecurity Programs

On September 15, 2015, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a National Exam Program Risk Alert (2015 Risk Alert) to provide broker-dealers and investment...more

Unprecedented Hacking and Trading Scheme Highlights Key Cybersecurity Lessons

On Aug. 11, 2015, federal prosecutors in the District of New Jersey and the Eastern District of New York unsealed indictments against nine individuals in the U.S. and Ukraine who were allegedly involved in a five-year,...more

The Practical Need for Managers of Micro Captives and the Allure of 'Off Label' Uses

Every tax season, the Internal Revenue Service releases a “Dirty Dozen” list of schemes that it considers abusive and widespread enough to present a systemic threat to its enforcement of the tax laws. This year’s list...more

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