Although the way firms and individuals are being prosecuted for bribery and corruption continues to evolve, the overall direction of travel is towards increased responsibility for the prevention of these activities. Most FCPA actions (83%) of 2017 involved bribery schemes that relied on third-party intermediaries such as agents, consultants, or contractors. And yet according to a recent survey, organizations are not responding fast enough by implementing the right policies and risk assessments.
March 12, 2018 posted by Aravo
March 02, 2018 posted by Aravo
It’s the billion-dollar question – what is on a regulator’s mind when they walk through the door of a firm? What kinds of things are they looking for – and is the firm prepared?
The focus on third party risk management by regulators has increased significantly over the past few years. The regulators themselves are providing some clear and coherent guidance on their expectations, such as: OCC Bulletin 2013-29, “Third-Party Relationships: Risk Management Guidance; FFIEC Appendix J: Strengthening the Resilience of Outsourced Technology Services. And, if you’re looking for a ‘crib-sheet’ of what the examiners are likely to be looking at, there’s also OCC Bulletin 2017-7: The OCC's Supplemental Examinations Procedures for Third Party Relationships.
In February 2018, Aravo brought together a panel of experts, two of whom were former US regulators, to talk about how supervisors are thinking about third party risk management. You can listen to the broadcast here – but we’ve also distilled it down into five key take-aways.
Topics: third party risk management, tprm, supplier risk, vendor risk, occ compliance, FFIEC, third party risk regulators, regulatory frameworks, risk and compliance, third party risk, third party compliance, third party vendor, concentration risk, fourth party risk, geopolitical risk, cyber risk, information security, compliance risk
February 05, 2018 posted by Aravo
Collaboration is a term that makes people either cheer or wince. However, today collaboration is essential to be a successful third party risk manager – the discipline has moved well beyond administrative box-ticking. Now, a strong culture of collaboration can help create the right environment to foster TPRM program excellence, and drive real value for organizations.
Topics: third party risk management, board of directors, board accountability, benchmarking, governance, third party governance, tprm, risk assessment, third party supplier, supplier risk, vendor risk, risk appetite, shared assessments, occ compliance, GDPR, third party risk assessment, standardization programs, gdpr processor, FFIEC, third party risk regulators, regulatory frameworks, internal audit, risk and compliance, third party risk, third party compliance, third party vendor
January 23, 2018 posted by Aravo
Third party risk management (TPRM) could be set to evolve at lightning speed over the next five years, according to Victoria Munoz-Titos, former EMEA, Risk and Control Services at AIG in London. The changes won’t just be accelerated by regulatory demands either. Rather, they will be propelled by a transformation to the way organizations work together, as financial services firms incorporate outsourcing and other types of third party relationships even deeper into their business strategies. Below are the top seven trends that Munoz-Titos sees changing the way firms engage with TPRM and their third-party relationships:
Topics: third party risk management, board of directors, board accountability, benchmarking, governance, third party governance, tprm, risk assessment, third party supplier, supplier risk, vendor risk, risk reporting, risk appetite
January 15, 2018 posted by Aravo
Third party risk management (TPRM) is a relatively new discipline for many financial services firms and so it’s no surprise that organizations are still navigating their way. As firms establish their third party risk programs, there’s many common pitfalls that they can fall into. Knowing about these helps you avoid them, so Aravo recently spent some time with third party management expert, John Bree, to expose some of the more common missteps that he has seen organizations make when it comes to setting up, or enhancing, a TPRM program.
Topics: third party risk management, board of directors, board accountability, benchmarking, governance, third party governance, tprm, Financial Services, risk assessment, third party supplier, supplier risk, vendor risk
November 29, 2017 posted by Aravo
Third party risk management is on a journey. A journey that is being accelerated and guided by increased regulatory attention.
Topics: operational risk, third party risk, risk-scoring, enterprise risk, performance scoring, third party relationships, reputational risk, regulatory risk, regulatory compliance, risk and compliance, supplier risk, Financial Services, vendor risk, occ compliance, Risk Management Framework, performance management program, third party supplier
November 22, 2017 posted by Aravo
In a speech last week at the Cyber Security Summit and Expo 2017, Nausicaa Delfas, Chief Operating Officer at the FCA, called out cyber risk as one of the FCA’s top priorities and noted its close intersection with supplier risk, and third, fourth and fifth party risk.
November 17, 2017 posted by David Rusher
Shared Compliance Communities gather supplier/third-party responses to standardized assessments with the promise of increased efficiencies and improved data quality. This concept isn’t necessarily new – at least not outside the U.S. - but there has been some recent development in terms of interest in the model.
October 06, 2017 posted by Aravo
With the strategic importance of engaging third parties in today's business landscape, coupled with the level of risk that they can bring to the enterprise, it should not be surprising that third party risk management is attracting greater focus from the C-suite and the Board of Directors.
According to the Institute of Collaborative Working, up to 80% of direct and indirect operating costs of a business can come from third parties, while up to 100% of revenue can come from alliance partners, franchisees and sales agents.
September 18, 2017 posted by Aravo
At the moment, the international approach to enforcement around bribery and corruption can seem uneven, at best and perhaps lax, at worst.