Third-Party Compliance

News & Analysis as of

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

New Year, New Focus on Enforcement: The U.K. Strengthens Anti-Bribery and Corruption Enforcement

U.K. regulators have started 2015 with a bang, promising increased cooperation among regulatory agencies, and tougher enforcement of financial crimes, with an emphasis on anti-bribery and corruption efforts....more

Building Your Third Party Due Diligence Checklist: The Right Pieces, Processes and Presumptions

A comprehensive approach to third party and vendor due diligence management is essential for any company conducting business globally. A strong due diligence program’s purpose is two-fold...more

FCPA Compliance and Ethics Report-Episode 95-interview with Scott Killingsworth on Private to Private Compliance Solutions [Video]

In this episode I visit with Scott Killingsworth, partner at BryanCave on his thoughts around the compliance solutions found in private-to-private compliance obligations. ...more

FCPA Compliance and Ethics Report-Episode 88, Internal Controls for Third Parties Under the FCPA, Part I [Video]

In this episode 88 of the FCPA Compliance and Ethics Report, I visit with noted internal controls expert Henry Mixon on the types of internal controls needed for third parties in a FCPA compliance program. ...more

Anti-Bribery and Corruption Compliance Practices

Compliance Week published its 2014 Anti-Bribery and Corruption Benchmarking Report, a survey of over 180 executives involved in ethics and FCPA compliance and internal audit. The Survey focused on risk, dealing with third...more

FCPA Compliance and Ethics Report-Episode 64-Managing the Third Party Relationship Under the FCPA, Part II [Video]

In this episode I continue my review of the five steps of managing third parties under the FCPA. In this part II, I discuss steps 3-5....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

Mitigating Bribery Risks With Financial Controls

Anti-corruption compliance is not as hard as it looks. In fact, by taking a step back, compliance professionals can gain insights. At the direction of compliance professionals, companies like to develop and adopt...more

BBB Warns Advertisers and Web Publishers to Take Responsibility for Behavioral Advertising Disclosures

The Better Business Bureau (“BBB”) and the Direct Marketing Association (“DMA”) are in charge of enforcing the ad industry’s Self Regulatory Principles for Online Behavioral Advertising (“OBA Principles”), which regulate the...more

Third Party Risk in a Global Environment

Most organizations engage with hundreds, if not often thousands, of third party vendors, suppliers, agents and business partners, creating a daunting and ever-expanding scope of risk. This risk arises from: 1....more

The Mini-Correspondent Channel: Pros and Cons

Several years ago, our firm, Lenders Compliance Group, provided unique guidance to the mortgage division of a bank. The bank wished to build a special origination platform for its mortgage brokers. At that time, the...more

Bribery, Corruption, and Third Party Risks - What Can You Do.

Please see full Infographic below for more information....more

A Prescriptive Guide To Third Party Risk Management

The recent examples of compliance program credits for Morgan Stanley and Ralph Lauren have demonstrated that, more than ever, an effective compliance program can protect a company from criminal indictment and generate bottom...more

Drilling Down On Due Diligence: Raising The Bar

I am sure Justice Department and Securities and Exchange Commission lawyers sometimes sit back and marvel at the world they have helped create – Companies are devoting more resources to the due diligence process for screening...more

Companies Turning to Technology to Combat Third Party Risk

As technology continues to increase the efficiency of most operational tasks, it should come as little surprise that technology can now improve the labor-intensive process of managing third party risk. The days of manual...more

Managing And Minimizing Your Third-Party Risks

Let’s start with a few basic assumptions – we all know that third parties are often the most significant risk for corruption. ...more

Challenges Abroad: Ensuring Fair Working Conditions for Third Parties

Since Rana Plaza garment factory collapsed in Bangladesh in April, killing 1,100 workers, many retailers have taken a closer look at the working conditions in their third party suppliers’ factories. European retailers like...more

Why Ignorance Isn’t Bliss When It Comes to Third Party Risk Management

In a recent webinar, Randy Stephens, VP of our Ethical Leadership Group, and Mike Vermilion, Senior Director of Third Party Risk Solutions, outlined a best practice approach to risk-adjusted due diligence for third party...more

SEC Order Against ISS

On May 23, the Securities and Exchange Commission charged Institutional Shareholder Services Inc. (ISS), a Maryland-based proxy adviser, with failure to safeguard its advisory clients’ confidential proxy voting information. ...more

Kroll And Compliance Week Survey Anti-Bribery And Anti-Corruption

Not many people realize that the US has elected one president who served as a prisoner of war....more

Lessons from Ralph Lauren: Designing Better Ways to Manage Third Party Risk

Trying to avoid the unusually strict import controls in Argentina and facilitate faster clearance of its products through customs, a subsidiary of Ralph Lauren Corp. was found to have bribed local officials between 2005 and...more

California Fair Claims Settlement Practices Regulations

Table of Contents: Introduction; PART ONE - Summary of Fair Claims Settlement Practices Regulations; Introduction; Claims Handling Duties; Acceptance or Rejection of Claims; Settlement Offers and Payment of Accepted...more

From The Compact Model To The Luxury Model – Managing Your Third Party Risk

I am currently attending the Hanson Wade Oil and Gas Supply Chain Compliance conference in Houston. The event is excellent and the presentations have been ‘spot on’ for the nuts and bolts of how to do compliance. As the...more

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