DE Under 3: Court Held That Workday Was an “Agent” to Employers Licensing its AI Applicant Screening Tools
Business Associates Here, There, and Everywhere: When Does Your Service Provider Really Need to Sign a HIPAA Business Associate Agreement?
In House Counsel: How To Measure the Effectiveness of Your Staffing Strategy
Sitting with the C-Suite: Identifying Opportunities to Leverage Human Capital
The CCPA for the Land Title Industry: Service Providers and Sale of Data Under the CCPA
Podcast - Risk Management: Troubleshooting & Problem Solving
Cybersecurity in the investment management industry
FCPA Compliance and Ethics Report-Episode 157-Training of Third Parties Under the FCPA
Special Report: The Hot-ish Swag at LegalTech New York 2015
The FCA, PRA, and Bank of England have published their finalised critical third party (CTP) rules (and accompanying guidance) in PS24/16 Operational resilience: Critical third parties to the UK financial sector....more
We recently dove into what vendor risk and vendor risk management entails. Once you understand that this is the risk that results from vendors, it’s simple to extend this and establish that vendor risk assessment (VRA), or...more
Vendor risk management (VRM), or third-party risk management, is the management, monitoring, and evaluation of risks that result from third-party vendors and suppliers of products and services. It’s a crucial initiative...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
The Microsoft FCPA settlement, while not significant in the total penalty of approximately $25 million, provides some important instructions concerning distributor and re-seller risks and mitigation strategies. ...more
Hiring third parties to conduct international business is appealing: Foreign business agents, consultants, distributors, and other groups facilitate business by speaking local languages, providing expertise, and accessing...more
Earlier this month news broke that the venerable British automaker Rolls-Royce had settled an international prosecution alleging that the company’s third-party intermediaries bribed local officials in Asia. The company agreed...more
Just 43 percent of organizations surveyed in NAVEX Global’s 2016 Ethics & Compliance Third Party Risk Management Report said they evaluated third parties before engaging with them—down from 68 percent in 2015....more
Seventy-five percent of respondents in the 2016 Ethics & Compliance Third Party Risk Management Benchmark Report rejected at least one third party as a business partner last year because of high risk factors identified in due...more
On September 15, 2015, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a National Exam Program Risk Alert (2015 Risk Alert) to provide broker-dealers and investment...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
The building blocks of any Foreign Corrupt Practices Act (FCPA) anti-corruption compliance program lay the foundations for a best practices compliance program. For instance in the lifecycle management of third parties, most...more
How to make the case for implementing third party compliance training in your organization. A recent article in the San Francisco Chronicle profiled Jay Jorgensen, the new Global Chief of Compliance at Walmart. The...more