Day 12 of One Month to Better 3rd Party Management-Data Analytics and Ongoing Monitoring of Third Parties

Thomas Fox - Compliance Evangelist
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Next I consider at how data analytics can be used to help detect or prevent bribery and corruption where the primary sales force used by a company is third parties. A clear majority of Foreign Corrupt Practices Act (FCPA) violations and related enforcement actions have come from the use of third parties. While sham contracting (i.e. using a third party to conduit the payment of a bribe) has lessened in recent years, there are related data analysis that can be performed to ascertain whether a third party is likely performing See more +
Next I consider at how data analytics can be used to help detect or prevent bribery and corruption where the primary sales force used by a company is third parties. A clear majority of Foreign Corrupt Practices Act (FCPA) violations and related enforcement actions have come from the use of third parties. While sham contracting (i.e. using a third party to conduit the payment of a bribe) has lessened in recent years, there are related data analysis that can be performed to ascertain whether a third party is likely performing legitimate services for your company and is not a sham. There are several more complex analytics that can be run in combination to identify suspicious third parties, and some of the simplest can be to look for duplicate or erroneous payments.

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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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