third-party risk Archives - Corruption, Crime & Compliance

Uncategorized

21 May, 2024

Distribution Chains and Sanctions Compliance (Part II of IV)

Companies rely on robust distribution chains as an efficient mechanism to enter new markets without requiring a significant investment. Additionally, companies may maintain parallel sales activities in markets between their own sales staff and third-party distributors, agents, resellers and dealers. It is interesting how certain industries have evolved and relied on different models for use of third parties with the intent of reaching customers in...

Uncategorized

20 May, 2024

The Same Old Song with a Different Meaning — Third-Party Risks and Sanctions Compliance (Part I of IV)

Sorry to start a four-part series with a reference to music from our long-ago past. The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965 — Video Here). So, how does that relate to third-party risks? Well, bear with me here for a little. Legal and Compliance bloggers, compliance vendors, prognosticators, Compliance Podcasters, and everyone in the Paparazzi have written,...

General

30 May, 2023

Gartner Settles FCPA Case with SEC for $2.5 Million

The SEC has been racking up several FCPA enforcement actions. DOJ appears to be declining many of these cases. The division of enforcement appeared to follow a pattern – on larger cases with more pervasive violations, DOJ and the SEC would each bring an enforcement action; while on relatively “smaller” cases, the SEC would bring a case and the DOJ would decline to prosecute. This...

General

12 Oct, 2021

The Evolution of Third-Party Risk Management

Third-party risk management is a favorite topic for compliance professionals. And for good reason. Third parties create significant risks. To state the obvious, companies have less control over third parties than employees. But for many reasons companies engage third parties as a more effective solution than hiring employees. In this situation, risk multiplies exponentially. The third-party risk issue, however, has multiplied exponentially for a number...