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Unraveling Third Party Due Diligence

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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 ...
The two former posts related to successful compliance management looked at defining key terms/positioning the compliance role and getting out of the office to collect information. Today, we turn to deepening your understanding of the third step related to the process, namely getting prepared for foreseeable challenges.
(Want to get articles like this one by email?  Here is the sign-up!)  The second step on the way to achieving compliance management success is all about engaging with the people who are exposed to potential risks. After having defined key terms and positioned the role of the chief compliance officer (CCO), a CCO must collect information and conduct assessments outside the walls of his/her office ...
(Want to get articles like this one by email?  Here is the sign-up!) In [Part 1] Compliance Management Success Kit, the author outlined four important steps to establish focused and dynamic compliance processes every CCO should follow to successfully manage a company’s compliance program. This post looks at the first of the four steps on the way to achieving successful compliance management.