Blog

Doing the Right Thing - 5 Best Practices in Managing ABAC Third Party Risk

Managing third party bribery and corruption risk can be one of the more challenging aspects of both overall anti-bribery and anti-corruption (ABAC) and third party risk management (TPRM) programs. They are also closely intertwined. Organizational stakeholders – shareholders, regulators, customers, and interested bodies such as pressure groups – are focusing on both of these areas with increased intensity today. This is not surprising, as third parties represent one of the largest areas of ABAC risk exposure to a company, and their compliance failure can result in significant financial and reputational damage for the organization.

However, getting an ABAC program for third parties right – greatly reducing the probability of a risk event occurring – can often mean the need for an organization to substantially raise its game. Applying focus on ABAC compliance after an investigation or enforcement action is never the best approach, as the damage is already done.

Below are 5 important best practices that organizations around the globe are implementing within their ABAC third party risk management programs today:

Read More

Topics: FCPA, Anti-Bribery and Anti-Corruption, supplier due dilligence, ABAC compliance, vendor due dilligence, third party due dilligence, third party risk monitoring, compliance standards

OFAC Settlement Agreement  Highlights the Importance of Knowing Your 4th Parties

Eyelashes expose weaknesses in 4th party and supplier due diligence.

Today the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)  announced a settlement of $996,080 with e.l.f. Cosmetics, Inc. (“ELF”) of Oakland, California. ELF has agreed to settle its potential civil liability for 156 apparent violations of the North Korea Sanctions Regulations, 31 C.F.R. part 510 (NKSR).

Read More

Topics: third party risk management, tprm, reputation risk, supply chain risk, 4th party risk, sanctions, supplier due dilligence