Welcome to a special 5-part podcast series sponsored by Diligent. Over this series we will consider a risk-based approach to third-party risk management. Over this series I will visit with Michael Parker, the Director of Advisory and Consulting Services; Stephanie Font, Director of the Optimizations Group; Kairi Isse, Managed Services Group Manager; Adam Bailey, Senior Vice President, Product Management and Alexander Cotoia, Associate at the Volkov Law Group. In this Part 5, I visit with Alexander Cotoia, a Regulatory and Compliance Manager at the Volkov Law Group, to consider how recent FCPA enforcement actions point toward the use cases for a robust third-party risk management system. 

In 2022, most FCPA-related enforcement actions involved third parties and required organizations to reprioritize third-party risk management. In this episode, we consider case studies involving ABB Limited, GOL Airlines, and Oracle, demonstrating the importance of understanding bribery and corruption schemes, making voluntary disclosures, and reassessing third-party risk management.

Key Highlights

·      How can organizations reprioritize third-party risk management as a core compliance function? 

·      What strategies can organizations use to avoid FCPA violations and maximize cooperation credit? 

·      How can organizations effectively assess the risks posed by potential business partners?

 Notable Quotes 

1.     "Don't put yourself in a position of being uncooperative with either the SEC or DOJ. Reassess your framework for third-party risk management holistically and hone in on the nature and quality of the collected information to objectively evaluate the totality of risks posed by a potential business partner to the organization."

2.     "You really can't afford to be complacent, especially as we have a new emerging consideration suspecting sanctions and export controls that have become core enforcement priorities of the federal government."

3.     "The critical question asked from a functional perspective is, is it adequate to objectively evaluate the totality of risks posed by a potential business partner to the organization?"

4.     "You must understand that third-party risk, especially regarding anti-bribery and corruption concerns, is a universal constant."

 Resources

Alexander Cotoia on LinkedIn

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