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Unraveling Third Party Due Diligence

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Willie Stargell, the Hall of Fame Pittsburgh Pirate Outfielder, once said that hitting Steve Carlton, another Hall of Fame pitcher, was as difficult as eating soup with a fork. Now you don’t have to be a baseball enthusiast to get that analogy. This kind of reminds me of Due Diligence for purposes of anti-bribery and corruption: On the surface it does not seem like that daunting a task, but ...
Corruption risks take a variety of forms, from expensive gifts and entertainment to politically-connected suppliers and facilitation payments. While the same rules may apply to everyone in the company, they affect each role differently. For example, salespeople are likely to face different compliance challenges than those on the finance team, and require different training. But people tend to ...
ZTE Corp, a Chinese telecom company with annual revenue exceeding $15 billion, is rumored to be finalizing a guilty plea to pay hundreds of millions to the United States in conjunction with allegations of illegal sales to Iran.  Reuters first reported the pending plea today here.  Reuters’ source, who declined to speak on the record, suggested ZTE may be working with the Departments of Justice, ...
(Want to get articles like this one by email?  Here is the sign-up!)  Notwithstanding the importance of compliance programs to companies, there is no one-size-fits-all formula to design the perfect anti-corruption compliance program. This is where compliance risk assessments come into the picture; a risk assessment is a critical first step in developing an anti-corruption compliance ...
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 ...
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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