Five Steps to Implementing a Risk-Based Due Diligence Program

Greater enforcement of Anti-Bribery and Anti- Corruption (ABAC) laws around the world have increased the scope of corporate compliance department responsibilities. A major element of any corporate ABAC program involves the performance of due diligence on third-party intermediaries. And for good reason, regulators routinely uncover evidence that a corrupt act was committed by an intermediary acting on the company's behalf, both with and without the company's knowledge. According to an analysis conducted by Foreign Corrupt Practices Clearing House, more than 90% of investiga-tions and enforcement activity related to FCPA bribery cases over the past ten years involved a third-party.