Tagged: Third Party Risk Management

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)

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)

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’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...