Tagged: Third Party Risk Management

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, 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

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...

Episode 131 — Third-Party Risk Monitoring and Auditing Strategies

An effective third-party risk management program has to include robust monitoring and auditing strategies.  This episode is a companion to Episode 129 on creating a third-party risk profile. In this episode, Michael Volkov outlines strategies for monitoring and auditing your third-party population.

NAVEX Global Webinar: Third-Party Risk Management & Effective Controls

February 18, 2020 1 PM EST/10 AM PST Sign Up HERE A comprehensive third party risk management program integrates with ethics and compliance activities across the enterprise to provide an accurate and actionable view of risk exposure. Implementing a holistic approach to due diligence extends beyond third party screening and monitoring.  Effective risk management programs integrate with risk profiles across the organization, breaking down silos...

Webinar: Third-Party Risk Management — Practical Solutions to Due Diligence, Monitoring and Testing

Wednesday, December 18, 2019 12 NOON EST Sign Up Here As more companies implement automated solutions to manage their third-parties, compliance officers face a growing list of new challenges to managing third-party risk. The Justice Department and the Department of Treasury (OFAC) have elevated the importance of managing anti-corruption and sanctions risks by issuing compliance program guidance. As part of this new set of expectations,...

Episode 105 — Third-Party Risk Management: Interview of Bill Hauserman and Ted Datta, Bureau van Dijk

Listen to Episode 105 HERE. Bill Hauserman and Ted Datta from Bureau van Dijk, a Moody’s Analytics Company, join us for an interesting discussion on third-party risk management, issues surrounding beneficial ownership, trends in the industry and the importance of validating ownership and data quality.  Bill and Ted explain their interesting perspective on third-party risk challenges, regulator expectations and a fascinating view from the global...

Digging into High-Risk Distributors (Part II of II)

Compliance professionals are implementing their own monitoring and auditing strategies.  Internal audit does not have the resources nor the time to assume responsibility for this function.  If possible, internal audit may support, advise and assist in the monitoring and auditing functions.  Frankly, a partnership between compliance and internal audit in this area is ideal but compliance cannot wait for internal audit to join the mission. ...

Third-Party Risk Management: Managing the Information Flow

We are living in rapidly changing times.  I know it sounds trite but it is amazing when you witness rapid innovation and change.  Even in our narrow corner of life involving ethics and compliance, we can see change occurring right before our eyes. When you review due diligence and third-party risk management, there has certainly been significant advances in capabilities to identify risks, uncover relevant...

Join Us for a May 16, 2019 BVD Webinar: “Is “Power and Control” the New Beneficial Ownership?

What are the new best practices for third-party risk management? Join Michael Volkov, CEO of The Volkov Law Group; Bill Hauserman, Senior Director, Compliance Solutions, Bureau van Dijk, a Moody’s Analytics Company; and Ted Datta, Director, Governance, Risk and Compliance Solutions, Bureau van Dijk, for a live webinar on Thursday May 16, 2019, at 11 am EST/4 pm BST. Please sign up HERE.  New anti-corruption...