I end this one month series by taking things a different direction. Today I do not focus on third party risk management but on third parties as a compliance innovation source for your organization. It is universally recognized that third parties are your highest Foreign Corrupt Practices Act (FCPA) risk. What if you could turn your third party from a liability under the FCPA to an innovation partner to your compliance program? This is an area that not many compliance professionals have mined but once again in compliance, you are only limited by your imagination.

In an article in Third Party Management Review by Jennifer Blackhurst, Pam Manhart and Emily Kohnke, entitled “The Five Key Components for Third  party Innovation”, the authors asked “what does it take to create meaningful innovation across third party partners?” One reason compliance innovation with third parties can be so power is that it cannot only affect costs but can move to gain a competitive advantage. To do so companies need to see their third parties as partners and not simply as entities to be squeezed for costs savings.

Their findings identified five components common to the most successful innovation partnerships. They are: “(1) Don’t Settle for the Status Quo; (2) Hit the Road in Order to Hit Your Metrics; (3) Send Prospectors Not Auditors; (4) Show Me Yours and I’ll Show You Mine; and (5) Who’s Running the Show?”

Don’t Settle for the Status Quo

This means that you should not settle for simply the status quo in compliance. Innovation does not always come from a customer or even an in-house compliance practitioner. Here the key characteristics were noted to be “cooperative, proactive and incremental”. You need to be leading the compliance innovation discussion rather than falling from behind. If a third party can suggest a better method to make compliance more efficient or cost effective, particularly through a technological solution, it may well be something you should consider.

Hit the Road in Order to Hit Your Metrics

To truly understand your compliance risk from all third parties, you must get out of the ivory tower and hit the road. This is even truer when exploring compliance innovation. You do not have hit the road with the “primary goal to be the inception point for innovation” but through such interactions, innovation can come about organically, as a part of your ongoing third party relationship. There is little downside for a compliance practitioner to go and visit a third party and have a “face-to-face meeting simply to get to know the partner better and more precisely identify that partner’s needs.”

Send Prospectors Not Auditors

While an audit clause is critical in any third party contract, both from a commercial and FCPA perspective, this exercise should be considered as such. You can establish a point of contact as an innovation manager for your third parties” Every third party should have a relationship manager, whether that third party is on the sales side or the Supply Chain side of the business. Moreover, the innovation partners are “able to see synergies where [business] partners can work together for the benefit of everyone involved.”

Show Me Yours and I’ll Show You Mine

As with all relationships, trust plays an important role in third party compliance innovation, as “Firms in successful innovations discussed a willingness to share resources and rewards and to develop their partners’ capabilities.” The authors believe that “Through the process of developing trust, firms understand their partner’s strategic goals.” I cannot think of a more applicable statement about FCPA compliance. Another way to consider this issue is that if a third party partner has trust in you and your compliance program, they could be more willing to work with you on the prevent and detect prongs of compliance regimes. Top down command structures may well be counter-productive.

Who’s Running the Show?

This means “who is doing what, but also what each firm is bringing to the relationship in terms of resources and capabilities.” In the compliance regime, it could well lead to your third party taking a greater role in managing compliance in a specific arena or down a certain set of vendors. Your local third  party might be stronger in the local culture, which could allow it to lead to collaborations by other vendors in localized anti-corruption networks or roundtables to help move the ball forward for doing business in compliance with the FCPA or other anti-corruption laws such as the UK Bribery Act.

The authors ended by remarking, “we noticed that leveraging lean and process improvement was mentioned by virtually every firm.” This is true in the area of compliance process improvement, which is the essential nature of FCPA compliance. Another interesting insight from the authors was that utilization can increase through such innovation in the third party. Now imagine if you could increase your compliance process performance by considering innovations from your third parties?

The authors conclude by stating that such innovation could lead to three “interesting outcomes (1) The trust and culture alignment is strengthened through the partnership innovation process leading to future innovations and improvement; (2) firms see what is needed in terms of characteristics in a partner firm so that they can propagate the success of prior innovations to additional partners; (3) by engaging third party partners as innovation partners, both sides reap rewards in a low cost, low risk, highly achievable manner.” With some innovation, you may well be able to tap into a resource immediately available at your fingertips, your third party.

Three Key Takeaways

  1. Use your third parties as innovators to assist your compliance program.
  2. Change your thinking about third parties and make them your partners.
  3. Do not settle for the status quo.

 

This month’s podcast series is sponsored by Opus. Opus helps free your business from the complexity and uncertainty of managing the risks associated with your customers, vendors, and third parties. By combining the most innovative Third-Party Risk Management and Know Your Customer Compliance SaaS platforms with unparalleled data solutions, Opus turns information into action so your business can thrive. Opus solutions include Hiperos 3PM accelerator, the leading platform for

The Foreign Corrupt Practices Act (FCPA) world is littered with cases involving freight forwarders, brokers and agents in the shipping and express delivery arena. Both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have aggressively pursued third party business relationships where bribery and corruption have been found. This is particularly true where companies are required to deliver goods into a foreign country through the assistance of a freight forwarder or express delivery service. There are several major risk points.

These include:

  • Location, location, location;
  • Customs and other governmental agencies;
  • Aviation and postal regulators;
  • Business promotion expenditures for governmental officials;
  • Agents and sub-agents; and
  • Government accounts are a major part of express shipper customers so must analyze this as well.

How can a company respond to protect itself or at least reduce its potential FCPA risk with regarding to a logistics company, freight forwarder or express delivery company? Obviously having a thorough risk assessment program and due diligence program are critical. After determining risk, move to perform due diligence based upon this risk. However, there are some general questions that you should ask, both internally and to your prospective vendor.

  1. Relationship. What is your relationship with the third party? Is it purely arms-length? Is it sales agent making a solicitation? Is it a consortium, which may be a lower risk? Is it partnership of JV, if so what is your control? Is it subcontractor or supplier? All of these have different risk levels.
  2. Business Formation. What is the character of the third party? Is it a US based company, is it subject to a robust national compliance law? Is it private/public? Who else do they represent? Length of time in business? Who are the principals and are they governmental officials?
  3. Compensation. How do you compensate the third party? Is it bonus-based paid at the conclusion of a transaction? Will the representative have an expense account? If so how is it given to them, for instance will you pay on a lump sum v. verified expenditures? How will they be paid, local currency into a bank account, cash or check? What is the level of compensation? Are you over-compensating based upon the market; you are taking a chance that the third party could share it with others.
  4. Location. What is the geographic location and is it one of the usual suspects on the Transparency International Corruptions Perceptions Index (TI-CPI)?
  5. Industry. What is the industry or sector that you are engaged? This can be significant because certain industries/sectors such as infrastructure, medical industry, defense contractors are facing increased DOJ/SEC scrutiny.
  6. Process. What is the process by which the business opportunity arose? What is the bidding process? Who invited you? Is it an open bid? Did you respond to an RFP? Did you compromise you own standards to bid? Is there a mandated partner assigned by the foreign government?

After you ask some of these questions, investigate your risks and evaluate them; you should incorporate these findings into a contract with appropriate FPCA compliance terms and conditions. This contract should announce to your to third party freight forwarder/express supplier of your expectations regarding their compliance program. Your contract should also allow for management of the compliance relationship. Your contract should require training and certification by verified provider or by your company. Your company’s Relationship Manager should ensure the third party’s compliance with your company’s anti-bribery compliance program.

James Min, Vice President, Int’l Trade Law & Global Head of Trade Law Practice Group at DP-DHL Legal Department, developed a risk matrix for the freight forwarders/express delivery industry. In this Min analyzes risks by multiplying factors noted herein and thus scoring. This model shows that location should not be the sole criteria for risk. The factors in the Min Model are the performance of your company’s customers clearance brokers and how far that performance varies from the norm your company normally receives. In the below chart, +1.00 equals average clearance time. >1.0 equals faster than average and <1 means slower than average.

The Min Model

Country TI CPI Customs

Clearance

Performance

Variance from

Average Performance

Risk Score Risk Rank
A 55 .93 1.21 61.9 1
B 20 .76 0.89 13.5 3
C 54 .29 1.00 15.6 2
D 88 .12 0.7. 7.39 4

 

The key in this approach is how often the Customs Broker/Express Delivery Service varies above the average for customs clearance times. If the percentage of customs clearance performance is so great that your vendors variance is above 100% most of the time, this could be a Red Flag that bribery or corruption is involved. This should lead to further investigation, due diligence, or asking of questions of your vendor.

Almost every business transaction engaged in by a freight forwarder, express delivery service or customs broker, outside the US involves a foreign governmental official. Every time your company sends raw materials into, or brings them out of, a country there is an interaction with a foreign governmental official in the form of a Customs Official. Every customs transaction involves a payment to a foreign government and every transaction involves some form of a foreign governmental regulatory process. While the individual payment per transaction can be small, the amount of total transactions can be quite high, if a large volume of goods are being imported into a foreign country.

Conversely interacting with international tax authorities can present problems similar to those with customs officials, but the stakes can often be much higher since tax transactions may be less in frequency but higher in financial risk. These types of risks include the valuation of raw materials for VAT purposes before such materials are incorporated into a final product, or the lack of segregation between goods to be sold on the foreign country’s domestic market as opposed to those which may be shipped through a free trade zone for sale outside that country’s domestic market.

If you utilize the services of a third party for any of the transactions listed above, that company’s actions will go a long way in determining your company’s FCPA liability. You must have a thoughtful process and document that process.

Three Key Takeaways

  1. Express delivery services and freight forwarders present unique compliance risks.
  2. There must be a business justification to bring on new express delivery services or freight forwarders in high risk jurisdictions.
  3. Consider the Min Model (or something similar) as your risk matrix in this area.

This month’s podcast series is sponsored by Opus. Opus helps free your business from the complexity and uncertainty of managing the risks associated with your customers, vendors, and third parties. By combining the most innovative Third-Party Risk Management and Know Your Customer Compliance SaaS platforms with unparalleled data solutions, Opus turns information into action so your business can thrive. Opus solutions include Hiperos 3PM accelerator, the leading platform for third party risk management. To learn more, go to www.opus.com.

 

 

 

One of the issues in any compliance program is the compensation paid to a third party as FCPA exposure arises when companies pay money – either directly or indirectly – to fund bribe payments.  In the traditional intermediary scenario, the company funnels money to the agent or consultant, who then passes on some or all of it to the bribe recipient.  Often, the payment is disguised as compensation to the intermediary, and some portion is redirected for corrupt purposes.

When companies grant distributors uncommonly steep discounts, bribes can result either: 1) because the distributor is instructed by the company to use the excess amounts to fund corrupt payments; or 2) because the distributor pays bribes on its own, without the express direction or implicit suggestion from the company to do so, in an effort to gain some business advantage. The 2012 FCPA Guidance, it noted that common red flags associated with third parties include “unreasonably large discounts to third-party distributors”.  The distributor enforcement cases offer lessons to combat the scenario, which is where legitimate companies require assistance.

How can risk that distributors present be managed?  One mechanism is to install a distributor discount policy and monitoring system tailored to the company’s operational structure.  In virtually every business, there exists a range of standard discounts granted to distributors.  Under the approach recommended here, discounts within that range may be granted without the need for further investigation, explanation or authorization (absent, of course, some glaring evidence that the distributor intends use even the standard cost/price delta to fund corrupt payments).

Where the distributor requests a discount above the standard range, however, the policy should require a legitimate justification.  Evaluating and endorsing that justification requires three steps: (1) relevant information about the contemplated elevated discount must be captured and memorialized; (2) requests for elevated discounts should be evaluated in a streamlined fashion, with tiered levels of approval (higher discounts require higher ranking official approval); and (3) elevated discounts are then tracked, along with their requests and authorizations, in order to facilitate auditing, testing and benchmarking.  This process also works to more fully operationalize your compliance regime as it requires multiple and increasingly upper levels of management involvement, approval and oversight.

Capturing and Memorializing Discount Authorization Requests

Through whatever means are most efficient, a discount authorization request (“DAR”) template should be prepared.  While remaining mindful of the need to strike a balance between the creation of unnecessary red tape and the need to mitigate risk, the DAR template should be designed to capture a given request and allow for an informed decision about whether it should be granted.  Because the specifics of a DAR are critical to evaluating its legitimacy, it is expected that the employee submitting the DAR will provide details about how the request originated (e.g., whether as a request from the distributor or a contemplated offer by the company) as well as explain the legitimate justification for the elevated discount (e.g, volume-based incentive).  In addition, the DAR template should be designed to identify gaps in compliance that may otherwise go undetected (e.g., confirmation that the distributor has executed a certification of FCPA compliance).

Evaluation and Authorization of DARs

Channels should be created to evaluate DARs submitted.  The precise structure of that system will depend on several factors, but ideally the goal should be to allow for tiered levels of approval.  Usually, three levels of approval are sufficient, but this can expanded or contracted as necessary.  Ultimately, the greater the discount contemplated, the more scrutiny the DAR should receive.  Factors to be considered in constructing the approval framework include the expected volume of DARs and the current organizational structure.  The goal is to ensure that all DARs are vetted in an appropriately thorough fashion without negatively impacting the company’s ability to function efficiently. It also mandates the operationalization of this compliance issue into multiple disciplines within your organization.

Tracking of DARs

Once the information gathering, review and approval processes are formulated, there must be a system in place to track, record and evaluate information relating to DARs, both approved and denied.  This captured data can provide invaluable insight into FCPA compliance and beyond.  By tracking the total number of DARs, companies will find themselves better able to determine where and why discounts are increasing, whether the standard discount range should be raised or lowered, and gauge the level of commitment to FCPA compliance within the company (e.g., confirming the existence of a completed and approved DAR is an excellent objective measure for internal audit to perform as part of its evaluation of the company’s FCPA compliance measures).  This information, in turn, leaves these companies better equipped to respond to government inquiries down the road.

Rethinking approaches to evaluating distributor activities is but one of the ways that the increased number of enforcement actions, 2012 FCPA Guidance and Justice Department’s Evaluation of Corporate Compliance Programs document have provided insight into how the government interprets and enforces the FCPA.  This information, in turn, allows companies to get smarter about FCPA compliance.  With a manageable amount of forethought, companies who rely on distributors can create, install and maintain systems which allow them to spend fewer resources to more effectively prevent violations.  Moreover, these systems generate tangible proof of a company’s genuine commitment to FCPA compliance, by more fully operationalizing this aspect of their compliance program.

Many companies have been involved in FCPA enforcement actions because of distributors. This sales side channel does not receive the focus equal to that of commissioned sales agents. Yet it can present an equally large compliance risk. By using this DAR approach, you will have created a well-thought out process which will operationalize your compliance program around distributor compensation, in a manner which documents your decision-making calculus.

Three Key Takeaways

  1. The creation of well-thought out process which operationalizes your compliance program around distributor compensation, in a manner which documents your decision-making calculus is key.
  2. Require multiple levels of approval for an out of range distributor discount.
  3. Tracking distributor discounts globally make your company more efficient. 

 

This month’s podcast series is sponsored by Opus. Opus helps free your business from the complexity and uncertainty of managing the risks associated with your customers, vendors, and third parties. By combining the most innovative Third-Party Risk Management and Know Your Customer Compliance SaaS platforms with unparalleled data solutions, Opus turns information into action so your business can thrive. Opus solutions include Hiperos 3PM accelerator, the leading platform for third party risk management. To learn more, go to www.opus.com.

 

 

 

At some point, you will be required to terminate a third-party and there will be multiple legal, compliance and business issues to navigate going forward. If you are stuck doing it in the middle of a Foreign Corrupt Practices Act (FCPA) or Bribery Act investigation, such as Airbus is currently under with the UK Serious Fraud Office (SFO), there may well be some tension to do so and do so quickly. If you have not thought through this issue and created a process to follow before it all hits the fan, you may well be in for a very tough road.

The key theme in termination is planning. The Office of Comptroller of the Currency, OCC Bulletin 2013-29, said that regarding third-party termination, a bank should develop a “contingency plan to ensure that the bank can transition the activities to another third party, bring the activities in-house, or discontinue the activities when a contract expires, the terms of the contract have been satisfied, in response to contract default, or in response to changes to the bank’s or third party’s business strategy.”

In an article entitled “Breaking Up Is Hard To Do”, Carol Switzer related how to avoid pain by planning for the end of a third-party relationship. She said it all should begin with “an exit strategy, a transition plan or a pre-nup—whatever the title, it’s best to begin by planning for the end which, in the case of business at least, will always eventually come. Whether due to contract completion or material breach, turning over responsibility to another party, or abandonment of the contracted activity altogether, contract termination is an inevitable phase in the third-party relationship lifecycle.” Planning for the end is important because, “The more long term and layered the relationship, the more difficult it will be to disentangle. The deeper the third-party is embedded in and uses the confidential information of the company and its customers, the greater the risks presented by failing to design a smooth transition process.”

It should originate with clearly specified contract termination rights but that is only the starting point, “To work out a smooth transition, the plan must also include internal change management processes and policies, designated transition team members, contingencies, and adequate resources and time allowances.” Your corporate values must be protected by “clearly designating the disposition of shared intellectual property and infrastructure assets.” Next you need to think through your transition plan by “ensuring rights to hire or continue use of key contractor employees who have been servicing your account, arranging to bringing new contractors or internal managers up to speed, and filing any regulatory or other required notifications.” Finally, bear in mind that your reputation must be protected during this transition process “by controlling and planning for issuance of public statements and social media postings by terminated contractors or their employees, or the best laid transition plans may be for naught.”

You will also need to consider the business risks around the termination of a third-party, particularly on the sales side of your business. This may mean sitting down with a customer or group of customers to explain the reasons behind the termination. Obviously if your business team has not developed a relationship with the end-using customer, this can be a difficult and very problematic conversation.

Unless you are exiting a business sector or territory, you will need to replace the third-party. This means going through the entire five-step process with any potential sales agent or representative. Such planning needs to be built into your termination strategy. If the reason for termination is a contract violation or worse a FCPA violation, there may well be other notifications which are required, both internally and externally to government regulators. You have also been under some type of contractual nondisclosure language and so consultation with your legal counsel, once again both in-house and outside, may be required. Finally, never forgot the reputation damage by releasing such information, or conversely not disclosing it. Both sets of reasons may hurt your business reputation as well.

In addition to the above steps, there are some specific considerations you should take. In the area of data, data privacy and data accessibility, if a third-party has access to your network and systems, such access must be revoked. If your terminated third-party has physical data, you must plan for the return of your data to you in a format that is acceptable to you and is secure. If your data is confidential, you may want to require that it be returned in an encrypted format and via an encrypted channel. You should lay out the time frame for the return of any data.

Alternatively, you can specify that data be destroyed. If this is the route you take with your third-parties, it should be performed in a way which is secure so the data cannot be reconstructed at a later date, through the use of surreptitiously created backup or duplicate data. You should mandate the third-party provide to you a certificate of destruction that confirms the destruction of your data and the methods used for destruction. Information that must be retained should maintain the data protection requirements currently in place, or stronger if the applicable laws change during the time of retention.

Although rarely considered, the termination of a third-party relationship can be as important a step as any other in the management of the third-party lifecycle. While having the contractual right to terminate is a good starting point, it is only the starting point. You not only need to have a compliance and legal plan in place but a business plan as well. If you do not, the cost in both monetary and potential business reputation can be quite high.

Three Key Takeaways

  1. Termination of third parties is an oft-neglected part of the third party risk management process.
  2. Make certain you have the contractual right to terminate third parties written into your standard terms and conditions.
  3. Have a strategy in place for termination before everything hits the fan.

 

This month’s podcast series is sponsored by Opus. Opus helps free your business from the complexity and uncertainty of managing the risks associated with your customers, vendors, and third parties. By combining the most innovative Third-Party Risk Management and Know Your Customer Compliance SaaS platforms with unparalleled data solutions, Opus turns information into action so your business can thrive. Opus solutions include Hiperos 3PM accelerator, the leading platform for third party risk management. To learn more, go to www.opus.com.

One area that has bedeviled Chief Compliance Officers (CCOs) and compliance practitioners is how to determine the return on investment (ROI) for your compliance program regarding third parties. While it is still clear that third parties are the greatest risk in Foreign Corrupt Practices Act (FCPA) enforcement actions, senior management often wants to know what is the monetary benefit to the company for this type of risk management.

When you couple the request for ROI with the recent Department of Justice (DOJ) mandate for the operationalization of your compliance program, as articulated in the Evaluation of Corporate Compliance Programs, it may seem like a doubly daunting task. However the requirement for operationalization of your compliance program actually lends itself to formulating ROI around the risk management of third parties. This is because if you move the third-party compliance into the organization as a business process, with a technological solution, the ROI becomes not only clearer but easier to calculate going forward.

I recently read a study by Forrester Research Inc., suggested an approach for the anti-corruption compliance practitioner. In this study, Forrester compared the user experience, leading to a finding of a positive ROI for the technology user around third-party risk management. I found the approach and methodology used persuasive and valuable for the compliance professional to consider in evaluating such a process in your organization.

Some of the key findings readily translate across for the anti-corruption compliance practitioner. The first area was in risk assessments of third parties. If you are able to provide a technological platform, you can enhance both the speed and efficiency of your risk assessments on an ongoing basis. The decrease in time it would take for each risk assessment, both in terms of length and compliance department man-hours will yield an immediate cost saving for your compliance function.

Consider just two of the steps required in the lifecycle management of third parties, the questionnaire and due diligence. Both steps can be not only labor intensive to complete and analyze but the cycles of time spend sending out a questionnaire, receiving a completed form and then inputting the information into a spreadsheet for manual analysis can be quite time consuming. It usually involves the basic tools of spreadsheets, interviews, Internet searches and additional questionnaires. By tailoring your questionnaire to the specific risk areas and using logical question design you can reduce confusion and therefore decrease the cycle of response time. Additionally, in the final step of managing the relationship there is often not only a dearth of data but usually the data is in such a siloed format that (1) it cannot be utilized between corporate functions and (2) there can be no meaningful comparison across the third parties. Through standardized questions and responses, this data can be compared across the spectrum of third parties.

In addition to the increased efficiency in the compliance portion of this analysis, by operationalizing your third-party risk management in this manner, you increase business efficiency by bringing in more dollars more quickly for third parties on the sales side. For third parties on the Supply Chain side, the efficiencies turn on your use of their products or services more quickly in business critical elements of your company. Simply put, approving third parties and incorporating them into your business cycle will not only save your money more quickly and efficiently but also make you money more quickly and efficiently.

Using a tool that incorporates Software-as-a-Service (SaaS) platform would also allow a more comprehensive review of data and information for several reasons. Firstly the various types of data is not siloed but stored in a centralized platform. Second, having this type of data allows for not only an ongoing review of each third-party but also allows you to review historical trends. This enables you to move from detection to prevention and possibly even delivery of a prescriptive solution before an issue arises to a full-blown FCPA violation. You would also be able to garner a better understanding of relationships across industry sectors and countries with a bigger picture look.

Obviously you will need to set the parameters for the risks to be assessed but more clearly in the FCPA they deal with third parties who are or who have, as owners, Politically Exposed Persons (PEPs), the inability to account for discretionary funds such as marketing or other expenses was seen in a recent FCPA enforcement action, payments to offshore locations or unusual commission or other payments tied 100% to sales. Not only would your company have more and greater visibility into such issues but the range of third parties you could monitor would increase, perhaps at an exponential rate. As with the cost savings of the initial risk assessment, there would be similar savings for ongoing monitoring in the area of greater efficiency and need for smaller headcount from the compliance function to perform such ongoing monitoring.

The speed and robustness of this database is a key element in operationalizing your compliance program in the area of third parties. The prevent component of any compliance regime is improved as you would have better visibility into potential non-compliant third parties which you may have to discharge. You would also have the ability to work with non-compliant third parties to remedy any issues before they become legal violations and then recommend extra monitoring as appropriate.

Using the above as a guide the ROI calculation would be something along the lines of the number total number of hours spent on each risk assessment x the total risk assessments performed x the hourly rate of the compliance professional performing the services. So if you spend 20 hours on 50 risk assessments and the hourly rate for your in-house compliance professional is $100, the ROI is $100,000. Now just think of what that number would be around third parties if the SC third parties runs into the thousands. Even with a round number of 1,000 for such third parties, your ROI increases to $2MM. Of course you have to subtract out the cost for any technological solution but with these types of efficiencies, your ROI will still be quite impressive.

There are a wide variety of other factors that could increase your ROI, as detailed in the Forrester report, which include renewal assessments, ongoing monitoring, increase in business efficiencies for both your organization and the third parties, which would all work to uplift your ROI. Most critically you would demonstrate the operationalization of your compliance program into the very fabric of your organization.

Three Key Takeaways

  1. Why is it important to demonstrate ROI on your third party risk management program?
  2. Determining your ROI helps to demonstrate operationalizing your compliance program.
  3. Determining third party management program ROI can help to tear down compliance silos. 

 

This month’s podcast series is sponsored by Opus. Opus helps free your business from the complexity and uncertainty of managing the risks associated with your customers, vendors, and third parties. By combining the most innovative Third-Party Risk Management and Know Your Customer Compliance SaaS platforms with unparalleled data solutions, Opus turns information into action so your business can thrive. Opus solutions include Hiperos 3PM accelerator, the leading platform for third party risk management. To learn more, go to www.opus.com.