In this whitepaper, one of Asia’s leading risk management and background screening data specialist, Michael Short, shares his views on the necessity to conduct enhanced due diligence on third party intermediaries in the context of the Foreign Corrupt Practices Act (FCPA) and the UK ‘s Bribery Act (UKBA) of 2010. Full synopsis
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A spotlight on due diligence: how much is enough?
Due diligence is often cited as a ‘must have’ for any compliance programme but the exact components of a successful due diligence programme are rarely spelt out by regulators. This often leaves compliance professionals in the ‘no-mans land’ of knowing they have to do something to check the background of their international agents, vendors and distributors – but not sure what this actually entails. The aim of this paper is to analyse the level of due diligence that is viewed as adequate by regulators as part of demonstrating a comprehensive, consistent and auditable compliance programme and suggests how this may look in reality.
Areas of analysis include:
- The background of the FCPA and the UK Bribery Act
- What constitutes adequate procedures under the UKBA and due diligence
- What is expected for FCPA compliance and due diligence
- A case study of insufficient due diligence