A Third Party's Perspective on Third Party Risk
Privacy Issues from Third-Party Website Tags
Episode 329 -- Bryn Sedlacek from Aravo on TPRM Holistic Risks and Unified Visibility
Corruption, Crime and Compliance: Third-Party Risks and Sanctions Compliance
Compliance into the Weeds: Sustainability and Managing 3rd Party Risk
Episode 304 -- Nathalie Druckmann, VP at Certa, on Artificial Intelligence Third-Party Risk Management
One Month to More Effective Written Standards: Day 17 – Policies for Third-Parties
FCPA Compliance Report - Brad Hibbert on Prevalent’s 2023 3rd Party Risk Management Report
Innovation in Compliance - Improving Third - Party Risk Management with Paul Valente
One Month to a More Effective Compliance Program for 3rd Parties - Day 13 - Ongoing Monitoring of 3rd Parties
Corporate Compliance and Enforcement Hot Topics with IBM VP, Una Dean
Innovation in Compliance - Contracts as a Third-Party Risk Management Tool with Brad Hibbert
Cyberside Chats: There is a war in Europe. What does that mean for your cyber insurance policy?
Matt Kelly on Cybersecurity and Suppliers
Patty Houser on Supplier Codes of Conduct
Chris Ford on Compliance and Cloud Computing
Ashley Coselli and Daniel Wendt on Difficult Anti-Corruption Due Diligence Projects
Ronnie Kann and Trent Sandifur on Third-Party Monitoring
Susan Roberts on Creating a Compliance Program Book
Brian Lee on Compliance Spending
On May 3, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency (collectively, the agencies) released a guidebook aimed at assisting...more
The guidance outlines principles and key considerations for banking organizations as they navigate risks associated with third parties, including fintechs. On June 6, 2023, the Federal Deposit Insurance Corporation...more
Agencies Issue Final Guidance on Third-Party Risk Management - On June 6, the Federal Reserve, FDIC, and OCC issued final joint guidance (the Guidance) pertaining to banking organizations’ risk management of third-party...more
While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement. OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions. That is quite an increase...more
La Ley de Prácticas Corruptas en el Extranjero (“Foreign Corrupt Practices Act – FCPA”) prohíbe el pago de sobornos a funcionarios extranjeros para ayudar a obtener o retener negocios. Exige que las empresas cuyos valores se...more
The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business. It requires companies whose securities are listed in the US to maintain books and...more
Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more
Ericsson’s FCPA settlement is in the books (not the books and records). But it casts a significant shadow across the FCPA landscape. A pervasive and systemic culture of bribery is defined to reflect senior executive...more
Companies will often rely on a network of distributors to help sell their products in emerging markets. From a business economics standpoint, engaging a distributor is often more cost efficient than investing in a sales...more
Fresenius Medical came close to earning a declination under the FCPA Corporate Enforcement Policy. Unfortunately, Fresenius’ effort fell short — but it came close. Fresenius Medical operates more than 3700 dialysis clinics...more
Believe it or not, but companies are still struggling with third-party risk management systems. I know this sounds hyper-critical but many companies continue to hang onto paper due diligence systems (sometimes with or...more
The first lesson for the compliance practitioner is that you should actually test your compliance program in high-risk/high-profile situations. The unfurling team likely did practice their unfurling regime but apparently...more
On June 7, the Office of the Comptroller of the Currency (OCC) issued OCC Bulletin 2017-21 (Frequently Asked Questions to Supplement Bulletin 2013-29; Third-Party Relationships: Risk Management Guidance). This is the OCC’s...more
Of the wide range of challenges that compliance officers face with third parties, my favorite is: who “owns” third-party risk management? The truth is that different people within the enterprise feel different types of pain...more
Third party risk management is easily one of the most challenging risks for compliance officers. With all the attention and hype surrounding third party risk, companies have marshaled attention and resources to mitigate the...more
Ronald Reagan’s mantra with respect to US-Soviet relations in the 1980s applies with equal force to today’s world of due diligence. (I know it shows my age that I can recall this statement). Not all due diligence cases...more
In response to aggressive FCPA enforcement and recurring problems with third parties, companies have spent substantial resources and time to design and implement comprehensive ethics and compliance programs. A key part of...more
In this episode I discuss the training of third parties under the FCPA. I review the DOJ/SEC FCPA Guidance on this issue; the risk ranking of third parties to help deliver your training; the types of training you can utilize...more
What are the Risks? In an effort to heighten efficiency and cost effectiveness, many financial institutions choose to outsource certain services to third party vendors. While these providers often play a beneficial...more
Over this week I have looked at some issues related to compensation and methods from other disciplines that a compliance practitioner might use to test and then improve a company’s third party management regime. Today, I want...more
The definition of “effectiveness” for a third party risk management program is quickly changing — how is your organization keeping up? I usually avoid predicting the future because you are bound to get something wrong. ...more
A significant minority of states permit plaintiffs who win judgments against insured defendants to assert claims directly against the defendants’ insurers—including claims for extracontractual liability, based on alleged bad...more
In this episode, I continue my exploration of internal controls around third parties in a FCPA compliance program, with Henry Mixon. ...more
The GlaxoSmithKline PLC (GSK) corruption matter in China continues to reverberate throughout the international business community, inside and outside China. The more I think about the related trial of Peter Humphrey and his...more
At first, this case seems somewhat pedestrian – a lawyer sues her erstwhile law firm for employment discrimination. But then things get complicated. It turns out that the lawyer was employed by a law firm that was employed...more