The document discusses managing third party risks and compliance. It recommends defining third parties, counting them, assigning responsibility for oversight to business units, vetting third parties using standard tools like questionnaires and investigations, including compliance clauses in contracts, and maintaining a consistent approach to third parties to satisfy regulators. The document is from Matt Kelly, editor of Compliance Week, and provides guidance on third party risk management and compliance.
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Third party management
1. Matt Kelly
Editor & Publisher
Compliance Week
mkelly@complianceweek.com
@complianceweek
www.complianceweek.com
11 Nov. 2013
2. Compliance Week
Writing about how companies get into trouble, for those executives charged
with keeping them out of trouble.
Anti-corruption
Financial reporting
Regulatory compliance
Privacy
Risk management
Internal audit
Daily web updates, weekly e-newsletter, monthly magazine, annual conference
20,000 monthly print magazine subscribers
50,000+ unique visitors monthly to website
500+ conference attendees
www.complianceweek.com
11 Nov. 2013
3. First Challenges of Third Parties
How do you define third parties? Does
everyone know that definition?
How do you count third parties?
Use your accounting department as
best you can
Use your procurement department
www.complianceweek.com
11 Nov. 2013
4. Assign Responsibility for Third Parties
Who found these guys?
Determine which business units oversee
hiring, or just recommending, vendors
Push responsibility to business units
Expect fights on anti-corruption vetting;
redefine your policies & contracts
Use your procurement department
www.complianceweek.com
11 Nov. 2013
5. Vetting Third Parties
Use standard tools & techniques
Questionnaires
NGO Benchmarking Reports
State Department
Investigations
Weigh risks wisely
Size of market, type of product
Likelihood of regulatory scrutiny
New vendor? New market or product?
New executive on the project?
www.complianceweek.com
11 Nov. 2013
6. Once Theyre on Board
Contract clauses to consider
Right-to-audit, good
Right-to-terminate, better
Each brings its own risk!
What will regulators want to see?
Consistent approach to third parties
Awareness of potential risks
Efforts to reduce, remediate
www.complianceweek.com
11 Nov. 2013
7. Thank you!
Matt Kelly
Editor & Publisher
Compliance Week
mkelly@complianceweek.com
@complianceweek
www.complianceweek.com
11 Nov. 2013