In July, I will consider managing third-party risk in an operationalized compliance program. As any compliance professional knows, third parties continue to pose the highest risk under the FCPA. You must assess whether the company has a business reason for needing the third party in the transaction and what risks third parties pose, including their reputation and relationships with foreign government officials, if any. You should ensure that the terms of the contract with third parties accurately describe the services to be provided, the third party actually performs the work, and that their compensation is appropriate for the work performed in that industry and geographic region. Finally, you must continually monitor third-party relationships through updated due diligence, training, audits, and/or annual compliance certifications by the third party.

Three important findings:

1. Use the complete five-step third-party management process.
2. Make sure business development is on your side and involved.
3. Operationalize all further steps by involving representatives of the business unit.

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