Why “one and done” FCPA due-diligence is not enough.

In part II of my interview with Joe Spinelli, Senior Managing Director, Kroll, we continue to explore findings of the Kroll-Ethisphere 2017 Anti-Bribery and Corruption Benchmarking Report. In this interview, Joe shares:

  • The perils of ‘vetting and forgetting’ with respect to on-boarding and due-diligence.
  • The importance of internal monitoring,  and how that responsibility needs to be shared across the organization.
  • The necessity to empower front and middle-line management to ‘flag-up’ issues, including changes to the external risk environment, as quickly as possible.
  • The importance of creating a ‘speak-up’ culture so that changes in a third party’s risk profile are immediately flagged.
  • The need to know when due-diligence ‘lite’ is not going to provide a multinational with the depth of information that’s needed to make informed decisions.
  • How third parties circumvent even the most robust due-diligence and on-boarding programs and how to mitigate this misconduct.
  • What changes to the internal and/or external environment should trigger interval or ad-hoc monitoring.

If you missed part one of our interview, it can be found here.

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