Third-Party Due Diligence: Creating a Credible & Defensible Program

Ensuring compliance with anti-corruption statutes such as the U.S. Foreign Corrupt Practices Act (“FCPA”) or the U.K. Bribery Act is a complex task. That is all the more true particularly for how organizations oversee the third parties acting on their behalf.


The cornerstones for third-party oversight are due diligence and monitoring—but building those concepts into a credible compliance program requires a multi- pronged effort; one that aligns an organization’s people, processes, and technology to prevent and detect violations.


What’s more, achieving that credible third-party program remains an urgent compliance priority, as is spelled out in multiple guidance documents from the US Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”). The DOJ and SEC’s Guide to the U.S. Foreign Corrupt Practices Act, Second Edition (“The FCPA Resource Guide,” last revised July 2020) continues to be a blueprint for effective compliance programs today.

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