Last year brought several FCPA enforcement actions where the underlying due diligence performed on third parties was insufficient. While many companies have gone to automated due diligence as a part of their compliance program, in many cases that is insufficient. In this episode I visit with Scott Shaffer, Managing Director of the Kreller Group and Tom Engelhart, Director at the Kreller Group. We discuss the need to have a human perform substantive due diligence and perform an adequate evaluation. In this podcast we discuss:
- 2018 saw two FCPA enforcement actions this past year which focused on due diligence, Kinross and Panasonic Avionics. What do these enforcement actions communicate about the need for the human element in due diligence?
- How can a compliance professional evaluate when this human element is needed in due diligence?
- How does a compliance profession think through a high-risk entity, person or situation where enhanced due diligence is appropriate?
- Is due diligence a one-time or an ongoing process?
For additional reading, see Scott Shaffer’s blog post on Due Diligence Will Always be a Human Skill on the FCPA Blog.
See Scott Shaffer’s professional profile here.
See Tom Engelhart’s professional profile here.
For information on the Kreller Group, click here.