There is another illustrated series which may be of more use to the modern day compliance practitioner which can be found in Compliance Week Magazine. In the February 2012 edition OCEG President Carole Switzer continues her series on an illustrated six-part anti-corruption program. In this issue she focuses on third party due diligence. She begins by noting that one of the surest ways to develop and strengthen your anti-corruption compliance program, whether based upon the US Foreign Corrupt Practices Act (FCPA) or the UK Bribery Act is to discover “what you do not understand about the third-parties who help you to do business abroad.” She explains that if your company does not “expand its knowledge of activities of your business partners,” the Department of Justice (DOJ) or UK Serious Fraud Office (SFO) may well do so for you in an enforcement action. Switzer provides a six-step process with a nifty diagram attached to the article.
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