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Unraveling Third Party Due Diligence

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The year 2016 has set the record for FCPA enforcement; 27 companies paid about USD 2.48 billion to resolve FCPA cases. Indeed, prosecutors rely on large criminal fines for companies and jail time for executives to deter corruption offences. These direct costs, together with indirect damage to the company’s reputation and lost business opportunities, make compliance the more attractive alternative ...
The Las Vegas Sands Corporation has agreed to pay a $6.96 million criminal penalty to resolve a Department of Justice investigation relating to the Foreign Corrupt Practices Act (FCPA) in connection with business transactions in China and Macao.  Note that the SEC brought a separate action in April 2016 based on the same fact pattern and they paid USD 9 million.  Bottom line – these fines are ...
BROOKLYN, NY – Jan. 31, 2017 -- GAN Integrity Inc., a leading provider of compliance management software to enterprise businesses, today announced it has raised $9 million in growth financing led by Edison Partners.  NorthCap, Chicago Ventures, MissionOG, and Cultivation Capital also participated in the round.   GAN provides global companies with the most comprehensive compliance management ...
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Keeping in mind that approximately 97% of FCPA violations involve third party corruption, only a rigorous and meticulous third party due diligence program should be just good enough for companies to shield themselves from criminal and civil liability. Recently I heard that a rather large and fairly well known multi-national firm was having an anti-bribery risk assessment conducted and there was a ...
(Want to get articles like this one by email?  Here is the sign-up!) Effective compliance program info for value chain partners and regulators: Certain third parties also have need for reliable information that supports a fact-based conclusion by that third party that a functioning program exists and is operating. Those in a present or prospective value chain relationship want to know that they ...
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(Want to get articles like this one by email?  Here is the sign-up!) Program management info – for the Chief Compliance Officer (CCO):
(Want to get articles like this one by email?  Here is the sign-up!)  Compliance program reporting is undergoing dramatic change. Periodic reports based on compliance program status data that was weeks old used to be the norm – for presenting to management or the board, or around budget time.
(Want to get articles like this one by email?  Here is the sign-up!)  The fourth and last step to achieving successful compliance management for every chief compliance officer (CCO) is to Foster a Culture of Compliance. The term 'culture of compliance' is now appearing with regularity in the US Department of Justice’s (DOJ) and Securities and Exchange Commission’s (SEC) policy and enforcement ...