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Why continuous monitoring is crucial for TPRM

Tom Fox | January 7, 2019

Your corporate compliance program requires all third parties to be certified through a rigorous five-step process that is renewed every two years. But what happens during the interim period? If you are not actively monitoring your third parties at all times, you could be setting the organization up for a Foreign Corrupt Practices Act (FCPA) violation. Consider these three examples:

  1. Let’s say you have assured yourself that your third-party agent does not have any politically exposed persons as owners, beneficial owners, or principals. You’re confident of this fact at the start of the relationship, but are you monitoring it via public data resources on an ongoing basis? If you’re not, what happened to Hitachi in South Africa about a decade ago could happen to you. In that case, Hitachi’s third-party agent brought on board a member of the African National Congress and transformed the nature of the relationship, which ultimately led to an FCPA...
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