Under the FCPA, the UK Bribery Act and local laws in multiple markets, a company is liable for the actions of its business partners, suppliers, customers, and agents (“third parties”) performing services on its behalf.
A screening program designed to flag corruption-related concerns as well as issues regarding relevant sanctions, watch lists and blacklists is a best practice that addresses the inescapable risk of engaging in business transactions with third parties in markets around the world.
We have deep experience assessing client-specific screening needs, designing screening programs based on a company’s risk profile and plugging into client organizations to administer these essential programs, allowing clients to direct their valuable in-house resources to other priorities.
Our process and methodology, combined with an optimal (offshore and/or onshore) staffing model, ensures a company-tailored program and cost effectiveness. We become an extension of your in-house team, but without requiring the on-boarding, training and management.
Creating Policy
We provide guidance and create internal policies for business partner screening programs. This includes establishing a screening policy based on the audience parameters and on the risk threshold of the business. We develop risk mitigation measures for engaging state-owned enterprises, politically exposed persons, entities subject to sanctions and additional high-risk parties. We draft communications to both internal stakeholders and external third parties to outline screening expectations and responsibilities, emphasizing the importance of compliance and the risks of policy violations to both the business and individuals.
Executing A Third-Party Diligence Program
We establish standard operating procedures designed to identify key players, develop clearance thresholds for flags based on risk tolerance, and establish the roles and responsibilities for managing each stage of the screening process. Our team also supports every step of the program administration. We execute the screens, analyze and synthesize the results, escalate flags according to standard operating procedures and develop reports to document screening results. For any problem third parties, we manage, track and document next steps and resolution.
Additional Services
We can also assist with: Screening tool system review and selection, including for integration with other systems, foreign language capabilities, database and workspace requirements, communication and alert/reporting functionalities; System implementation, including alignment to company objectives, identifying and ensuring data migration, and developing a complete set of screening procedures; and Training and communication, including to inform key stakeholders and others impacted by the program and to raise awareness, set expectations and provide clear guidance on the screening process.
Improve your compliance while reducing cost
Design, set up and manage your world-class compliance program, leveraging our proven experience. We specialize in privacy, AML and third-party vendor screening.
Discover an agile technology-enabled approach that combines strategic perspective with optimized operational execution. Stay on top of changing regulations with AI-powered horizon scanning and policy updates. You can also scale your capabilities using our managed compliance services, with a global footprint for competitive pricing and worldwide coverage.
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