It may seem like a Herculean task — but it can be done. I regularly opine that mitigating sanctions risks for your third-party population is an easier task than doing so for your anti-corruption risks. One big reason — geography is an important limiter on sanctions risks. The ability to evade sanctions has to be financially practicable — for example, it makes no sense to...
Within the specific element discussions in HHS-OIG’s Guidance, are important operational details and strategies for an effective compliance program. GCPG provides important suggestions and innovations for consideration by all compliance professionals. Effective Lines of Communication The GCPG stresses the importance of an open line of communication between the compliance officer and entity personnel as a means to reduce potential fraud, waste and abuse. To this...
Chief compliance officers have access to a vast amount of data generated by their compliance programs. CCOs have to establish effective monitoring processes. A critical part of this process is to build a compliance program dashboard. This is a practical issue of real importance. In this Episode, Michael Volkov reviews this important issue.
Frankly, this is a topic that requires more than a single blog-post. Books and podcasts can be organized around this topic with helpful ideas and guidance. In this respect, I will try to synthesize some important ideas that may be helpful. We all know that many companies “monitor” their third-party risks, for example, by subscribing to data services as part of risk-management platform that notify...
As companies move forward on third-party risk management programs, and as automated third-party risk solutions are being implemented, compliance professionals have to re-examine and re-balance the allocation of resources and time among three separate functions: (1) onboarding due diligence; (2) monitoring third-party conduct; and (3) review and audit of third-parties. Over the last ten years, companies have focused on initial due diligence and onboarding procedures,...
In the technology age in which we live, CCOs often come face to face with a new phenomenon – too much information or data. TMI is not something to laugh at nor ignore. CCOs often face situations where they need to understand what is occurring through a monitoring or audit function. In those cases, CCOs have to decide whether it is worth the cost in...
In response to aggressive FCPA enforcement and recurring problems with third parties, companies have spent substantial resources and time to design and implement comprehensive ethics and compliance programs. A key part of this effort was to implement robust due diligence programs to screen and identify potential risks created by third party intermediaries. Hui Chen, DOJ Compliance Counsel, called 2015 “The Year of Due Diligence.” Many...
I have never let my schooling interfere with my education – Mark Twain (unverified). Everything has its limit–iron ore cannot be educated into gold. – Mark Twain (verified) Board members believe they know what they need to know. That is why they were asked to serve on the board. Unfortunately, like many issues today, confidence does not mean competency. Corporate boards are increasing their focus...
