News & Analysis as of

Third-Party Foreign Corrupt Practices Act (FCPA) Risk Management

NAVEX

Sanctions are the “New” FCPA – How this Era of Enforcement Shapes Third-Party Risk Management

NAVEX on

In the summer of 2022, Deputy Attorney General Lisa Monaco – a veteran prosecutor and currently number two at the helm of the U.S. Department of Justice (DOJ) – began to describe the enforcement of sanctions regulations as...more

NAVEX

What a New SEC Enforcement Sweep Is Really Telling Us

NAVEX on

Attention all compliance officers at large technology companies – have you checked your mail lately? Because you might find a letter from the Securities and Exchange Commission with FCPA risk written all over it....more

Vinson & Elkins LLP

Updated DOJ Guidance on Devices and Ephemeral Messaging

Vinson & Elkins LLP on

On March 3, 2023, the Department of Justice (“DOJ”) issued long-awaited guidelines on how it will evaluate whether companies have implemented appropriate guidance and controls on the use of personal devices and third-party...more

The Volkov Law Group

Episode 120: Interview of NAVEX Global Third-Party Risk Officials: Chris Bailey and Stephen Gooding

The Volkov Law Group on

Global companies face extraordinary risks through their reliance on third-party agents, distributors, consultants and vendors/suppliers. Federal prosecutors and regulators have had a record year in FCPA and sanctions...more

Thomas Fox - Compliance Evangelist

Holmes Debuts and How Business Ventures are Different Risks Than Third-Parties

Whether they are Joint Ventures (JVs), partnerships, franchises, team agreements, strategic alliances or one of the myriad types of business relationships a U.S. company can form outside the U.S., they present diverse risks...more

NAVEX

Classifying Your Third Parties: An Essential Third-Party Due Diligence First Step

NAVEX on

From a corruption risk perspective, companies should be looking at their third parties that act in a representative capacity. Look no further than the 2018 FCPA enforcement actions to date for examples, all of which have...more

NAVEX

Third-Party Risk Management Decisions Need Context to Maximize ROI

NAVEX on

Effective third-party risk management has evolved beyond just identifying red flags. Today, mature programs know how to surface as well as prioritize their risk. Prioritization enables programs to apply resources and due...more

Thomas Fox - Compliance Evangelist

Day 17 of One Month to More Effective Continuous Improvement-Financial Health Monitoring

Continuous improvement can take many ways, shapes and forms. Typically, when it comes to third-party risks, a Chief Compliance Officer (CCO) or compliance professional will consider the ownership structure to see if there is...more

Thomas Fox - Compliance Evangelist

The Compliance Oversight Review Committee

This week has evolved into an exploration of different types of compliance committees a company might employ to make their compliance function more effective. On Monday, together with Baker Hughes Incorporated (BHI) Chief...more

The Volkov Law Group

Due Diligence Basics – Beneficial Ownership

The Volkov Law Group on

I hate to be the harbinger of bad news; that is against my nature; I am naturally an optimistic person. As I always say, there are solutions to every problem....more

The Volkov Law Group

DOJ and SEC Raising the Stakes on Third Party Risk Management

The Volkov Law Group on

If you review the last ten years of FCPA enforcement, the unmistakable pattern is rising expectations with regard to corporate compliance programs, particularly with regard to third party due diligence and risk management....more

The Volkov Law Group

When Diligence is Not Given its “Due”

The Volkov Law Group on

I find myself quibbling with compliance terms – hyper focus on small issues is not a positive trait. I often urge clients and colleagues to focus on issue of more significance and leave the smaller ones for another day....more

NAVEX

Building Your Third Party Due Diligence Checklist: The Right Pieces, Processes and Presumptions

NAVEX on

A comprehensive approach to third party and vendor due diligence management is essential for any company conducting business globally. A strong due diligence program’s purpose is two-fold...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 88, Internal Controls for Third Parties Under the FCPA, Part I

In this episode 88 of the FCPA Compliance and Ethics Report, I visit with noted internal controls expert Henry Mixon on the types of internal controls needed for third parties in a FCPA compliance program. ...more

Thomas Fox - Compliance Evangelist

The Mann Gulch Fire and How Far Down the Chain Do You Need to Go?

Robert Sallee died last week. A smoke jumper, he was the last survivor of the Mann Gulch Fire, one of the worst disasters in the history of the US Forest Service. Sallee’s story and that of the Mann Gulch Fire was detailed in...more

NAVEX

Third Party Risk in a Global Environment

NAVEX on

Most organizations engage with hundreds, if not often thousands, of third party vendors, suppliers, agents and business partners, creating a daunting and ever-expanding scope of risk. This risk arises from: 1....more

NAVEX

A Prescriptive Guide To Third Party Risk Management

NAVEX on

The recent examples of compliance program credits for Morgan Stanley and Ralph Lauren have demonstrated that, more than ever, an effective compliance program can protect a company from criminal indictment and generate bottom...more

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