Managing Your Third Parties in a FCPA Compliance Program

The building blocks of any Foreign Corrupt Practices Act (FCPA) anti-corruption compliance program lay the foundations for a best practices compliance program.For instance in the lifecycle management of third parties, most compliance practitioners understand the need for a business justification, questionnaire, due diligence, evaluation and compliance terms and conditions in contracts.

However, as many companies mature in their compliance programs, the issue of third party management becomes more important. It is also the one where the rubber meets the road of actually doing compliance.

In the March/April issue of Supply Chain Management Review is an article by Mark Trowbridge, entitled “Put it in Writing: Sharpening Contracts Management to Reduce Risk and Boost Supply Chain Performance”, that provides some useful insights into the management of the third party relationship. While the focus of the article was about having a “strategic approach to contracts management” I found the author’s “five ways to start professionalizing your approach to outsourcing contracts” as steps a compliance practitioner can use in the management of third party relationships, both on the sales side and those which come into your company through the Supply Chain.

By taking his analysis into the compliance realm, I believe there are concrete steps you can take going forward. The key is to have a strategic approach to how you structure and manage your third party relationships. This may mean more closely partnering with your third parties to help manage the anti-corruption compliance risk. It would certainly lead towards enabling your company to “control risk while optimizing the performance” of your third parties. To achieve these goals, I have revised Trowbridge’s prescriptions from suppliers to third parties.

I ...

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