31 Days to a More Effective Compliance Program - Day 16 | The third-party risk management process

Thomas Fox
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As every compliance practitioner is well aware, third parties still present the highest risk under the FCPA. The 2020 Update devotes an entire prong to third-party management. You must have a process for the full life cycle of third-party risk management. There are five steps in the life cycle of third-party risk management, which will fulfill the DOJ requirements as laid out in the 2020 FCPA Resource Guide and in the Hallmarks of an Effective Compliance Program. They five steps in the lifecycle of third-party management See more +
As every compliance practitioner is well aware, third parties still present the highest risk under the FCPA. The 2020 Update devotes an entire prong to third-party management. You must have a process for the full life cycle of third-party risk management. There are five steps in the life cycle of third-party risk management, which will fulfill the DOJ requirements as laid out in the 2020 FCPA Resource Guide and in the Hallmarks of an Effective Compliance Program. They five steps in the lifecycle of third-party management are: 

Business Justification by the Business Sponsor;

Questionnaire to Third-party;

Due Diligence on Third-party;

Compliance Terms and Conditions, including payment terms; and

Management and Oversight of Third Parties After Contract Signing.

Three key takeaways:

1. Use the full 5-step process for third party management.

2. Make sure you have business development involvement and buy-in.

3. Operationalize all steps going forward by including business unit representatives. 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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