31 Days to a More Effective Compliance Program - Questionnaire

Thomas Fox
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The next step in the five-step process is the questionnaire. The term ‘questionnaire’ is mentioned several times in the 2020 FCPA Resource Guide. It is generally recognized as one of the tools that a company should complete in its investigation to better understand with whom it is doing business. The questionnaire should be mandatory step for any third-party that desires to work with your company as it mandates the proposed business partner, commit to certain required information in writing prior to beginning the due diligence See more +
The next step in the five-step process is the questionnaire. The term ‘questionnaire’ is mentioned several times in the 2020 FCPA Resource Guide. It is generally recognized as one of the tools that a company should complete in its investigation to better understand with whom it is doing business. The questionnaire should be mandatory step for any third-party that desires to work with your company as it mandates the proposed business partner, commit to certain required information in writing prior to beginning the due diligence process. Remember if a third-party does not want to fill out the questionnaire or will not fill it out completely you should not walk but run away from doing business with such a party.

Three key takeaways:

1. You must have enough information to fully identify the owners, UBOs and related parties to determine if there is foreign official involvement.

2. All commentary on best practices compliance programs requires questionnaires.

3. If a third-party refuses to fully respond to your questionnaire, run, don’t walk away from the proposed relationship. See less -

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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