How Does Your Third Party Due Diligence Program Measure Up
1. HOW DOES YOUR
THIRD PARTY
DUE DILIGENCE
PROGRAM
MEASURE UP
BENCHMARK AGAINST THE ANONYMOUS
INDUSTRY POLLING RESULTS FROM
ACI’S 32ND FCPA CONFERENCE | NOVEMBER 2015
FCPACONFERENCE.COM
2. DO YOU TAILOR YOUR DUE
DILIGENCE PROGRAM DEPENDING
ON PERCEIVED LEVEL OF RISK?
YES: 86%
NO: 8%
IN CERTAIN SITUATIONS: 6%
AMERICAN CONFERENCE INSTITUTE'S
INTERNATIONAL CONFERENCE ON THE
FOREIGN CORRUPT PRACTICES ACT |WASHINGTON, DC
FCPACONFERENCE.COM
132 ATTENDEES ANSWERED:
3. WHO DOES THE DUE DILIGENCE
ON THIRD PARTIES AT YOUR
COMPANY?
ALL CENTRALIZED IN-HOUSE (I.E., COMPLIANCE): 13%
ALL DE-CENTRALIZED IN-HOUSE (I.E., BUSINESS UNIT): 7%
AN OUTSIDE VENDOR (E.G., TRACE INTERNATIONAL): 17%
A COMBINATION OF THE ABOVE: 64%
AMERICAN CONFERENCE INSTITUTE'S
INTERNATIONAL CONFERENCE ON THE
FOREIGN CORRUPT PRACTICES ACT |WASHINGTON, DC
FCPACONFERENCE.COM
120 ATTENDEES ANSWERED:
4. HOW MANY THIRD PARTY
AGENTS/VENDORS ARE "IN SCOPE"
FOR FORMAL VETTING UNDER
YOUR COMPLIANCE PROGRAM?
0-99: 18%
100-499: 28%
500-999: 13%
MORE THAN 1000: 41%
AMERICAN CONFERENCE INSTITUTE'S
INTERNATIONAL CONFERENCE ON THE
FOREIGN CORRUPT PRACTICES ACT |WASHINGTON, DC
FCPACONFERENCE.COM
109 ATTENDEES ANSWERED:
5. WHAT IS THE ANNUAL BUDGET
FOR YOUR ANTI-CORRUPTION
COMPLIANCE TEAM?
NONE: 6%
$0-$99,999: 14%
$100,000-$499,999: 29%
500,000-$999,999: 8%
$1 MILLION - $2 MILLION: 14%
MORE THAN $2 MILLION: 30%
AMERICAN CONFERENCE INSTITUTE'S
INTERNATIONAL CONFERENCE ON THE
FOREIGN CORRUPT PRACTICES ACT |WASHINGTON, DC
FCPACONFERENCE.COM
87 ATTENDEES ANSWERED:
6. HOW OFTEN DO YOU UPDATE DUE
DILIGENCE FILES ON THIRD
PARTIES WHICH YOU HAVE
ENGAGED?
EVERY YEAR: 11%
1-2 YEARS: 25%
2-3 YEARS: 26%
NEVER: 13%
IT DEPENDS ON HOW MANY "RED FLAGS" ARE ASSOCIATED WITH
THE THIRD PARTY: 25%
AMERICAN CONFERENCE INSTITUTE'S
INTERNATIONAL CONFERENCE ON THE
FOREIGN CORRUPT PRACTICES ACT |WASHINGTON, DC
FCPACONFERENCE.COM
106 ATTENDEES ANSWERED:
7. HOW OFTEN DO YOU CONDUCT
FCPA COMPLIANCE TRAINING
PROGRAMS FOR YOUR THIRD
PARTIES?
EVERY YEAR: 18%
1-2 YEARS: 22%
2-3 YEARS: 9%
NEVER: 26%
IT DEPENDS ON HOW MANY "RED FLAGS" ARE ASSOCIATED WITH
THE THIRD PARTY: 26%
AMERICAN CONFERENCE INSTITUTE'S
INTERNATIONAL CONFERENCE ON THE
FOREIGN CORRUPT PRACTICES ACT |WASHINGTON, DC
FCPACONFERENCE.COM
90 ATTENDEES ANSWERED: