Tagged: Third Party Risk Management

Episode 304 — Natalie Druckmann, VP from Certa, on Cutting Edge Third-Party Risk Management

Episode 304 — Natalie Druckmann, VP from Certa, on Cutting Edge Third-Party Risk Management

Natalie Druckmann, Vice President at Certa, joins Michael Volkov to discuss third-party risk management and the use of advanced artificial intelligence to implement effective risk mitigation strategies. Natalie sets the strategy for Certa’s expansion into the EMEA markets and growing Certa’s customer base with the use of Certa’s advanced AI tool — CertaAssist. CertaAssist’s suite of intelligent solutions include: The initial roll-out of CertaAssist has...

Top Compliance Reminders from 2023 FCPA Enforcement

Top Compliance Reminders from 2023 FCPA Enforcement

While 2023 was a relatively slow year in FCPA enforcement, the DOJ and SEC settlements announced throughout the year set out a list of important ethics and compliance reminders. While these may seem obvious to everyone, I hope they stimulate further reflection and analysis to inform FCPA compliance practitioners as they prepare for the next year. Third-Party Risk Management:  DOJ and the SEC FCPA enforcement...

Webinar: Breaking Down and Managing Your Third-Party Risks

Webinar: Breaking Down and Managing Your Third-Party Risks

March 14, 2023 12 Noon EST SIGN UP HERE In the ever-changing global economy, and in the aftermath of the pandemic and Russia’s invasion of the Ukraine, third-party risks continue to present significant risks and challenges. At the same time, global companies face escalating enforcement risks from the United States and foreign law enforcement. It is more important than ever for companies to embed third-party...

Lessons Learned from the Honeywell FCPA Settlement (Part III of III)

Lessons Learned from the Honeywell FCPA Settlement (Part III of III)

The Honeywell FCPA settlement underscored a number of important issues – lessons learned for compliance professionals.  Every FCPA case carries important lessons learned, but some more than others.  The Honeywell case with its focus on the large project in Brazil, and the contractual dispute in Algeria both provide important pointers relating to third party risk management.  In addition to the third party issues, however, Honeywell...

Adjusting Your Perspective — Identifying Your Real Third-Party Risks (Part II of V)

Adjusting Your Perspective — Identifying Your Real Third-Party Risks (Part II of V)

Compliance professionals are always looking for ways to collaborate and support internal business partners.  Through the years, compliance professionals have devoted significant energy to building partnerships with the business.  Compliance has and should continue to build a strong relationship with business as a meaningful value-add.  This process has been accelerated by the Covid and Ukraine crises and increasing cyber risks stemming from data breaches and...

Renewing Your Third-Party Risk Management Vows — A Real World Perspective (Part I of V)

Renewing Your Third-Party Risk Management Vows — A Real World Perspective (Part I of V)

When you get on the mailing lists for legal and compliance products, seminars, conferences and general palabra, I usually become transfixed.  Millions of marketing and promotion dollars are being spent in an attempt to distinguish or highlight the subject of third-party risk, position a product or highlight the expertise of a speaker.  Sometimes I take the time to read some of the emails — to...

WPP, the Largest Global Advertising Group, Settles FCPA Charges with SEC for $19.2 Million (Part I of III)

WPP, the Largest Global Advertising Group, Settles FCPA Charges with SEC for $19.2 Million (Part I of III)

After a long hiatus, the SEC announced a settlement with WPP plc, the world’s largest advertising group, for FCPA violations in India, China, Brazil and Peru for $19.2 million.  The SEC’s resolution charges WPP with violations of the anti-bribery, books and records and internal accounting controls provisions of the FCPA. The Justice Department’s investigation of WPP appears to be ongoing. WPP has dual headquarters, in...

Deutsche Bank FCPA and Fraud “Spoofing” Settlement: A Review of Deutsche Bank Conduct (Part II of II)

Deutsche Bank FCPA and Fraud “Spoofing” Settlement: A Review of Deutsche Bank Conduct (Part II of II)

Deutsche Bank’s ethics and compliance function faces numerous challenges.  Deutsche Bank has a storied record of scandals, government enforcement actions and failures to abide by prior deferred prosecution agreements (DPAs).  When you review these matters, Deutsche Bank’s track record reflects serious culture and control deficiencies, including participation of high-level executives in bribery schemes.  Deutsche Bank’s continuing legal and compliance failures are likely to continue unless...

Deutsche Bank Agrees to Pay $130 Million to Resolve FCPA and Fraud Cases (Part I of II)

Deutsche Bank Agrees to Pay $130 Million to Resolve FCPA and Fraud Cases (Part I of II)

Deutsche Bank, the infamous German bank connected to President Trump, settled FCPA and fraud cases with the Justice Department and the SEC, and agreed to pay a total of $130 million.  The settlement included resolution of fraud charges against Deutsche Bank relating to a commodities fraud scheme, commonly referred to as “spoofing.” Under the global resolution, Deutsche Bank agreed to pay: (1) criminal penalties of...

Letting Third Parties Do the Dirty Work

Letting Third Parties Do the Dirty Work

We all know it when we see it – a recurring fact pattern in which a company enlists a corrupt third party intermediary for one purpose (and one purpose only) – to pay a bribe.  Let me give you a few examples. Cognizant Technology In the Cognizant Technology FCPA enforcement action, the former President and General Counsel directed the scheme with two other C-Suite officers...