Addressing AML Risks in Your Third-Party and Vendor/Supplier Relationships (Part II of III)
Global companies should incorporate AML risks into their risk analysis of their third-party distributors, agents and other intermediaries. The basic questionnaire, due diligence risk analysis, contractual provisions, training, and partner code of conduct should reflect attention to this risk. To the extent that global companies rely on a network of third-party distributors and sub-distributors, global companies should include contractual provisions to flow-down policies and requirements...