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THIRD PARTY DUE DILIGENCE

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As the legislative landscape across many world economies becomes increasingly solidified in the regulatory sense, organisations that are expanding into the global markets need to be able to meet these challenges.  For one, rising third party corruption has brought on more enforcement actions than ever before.  Third parties (individuals & entities alike) can be candidates to act on receiving or offering bribe either on their own volition or be primed as conduit for corruption. 

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Regulators know too well that what they do represents their business network - this could mean that your organisation's business rationale or association with them will be under the spotlight for purported intermediary dealings that involve corruption.  And looking beyond corruption legislations, other hotspots like money laundering & terrorism financing, cybersecurity breach, racketeering, etc. are not far behind from the regulatory enforcement radar.  When you have little or no control over third party misconducts, your organisation can be held liable for them. 

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Red Flags

VAGUE BUSINESS INTEGRITY

Third parties having not substantiated their capabilities in the performance of services, instead acquire contractors with actual expertise to perform services on behalf of them in earning your business. ​Unlicensed third parties who `broker' business  transactions between the government entities & corporations and would command success fees or commissions for such `services'.

INAPPROPRIATE PAYMENT PRACTICES

Where third parties would instruct for payments to be made in cash only or to off-shore bank accounts or to multiple bank accounts not belonging to their business operations. They are known to make facilitation payments or prohibited payments to government officials to `get things done'.  ​Unusual advanced payments being requested.

APPREHENSION

They do not cooperate in your due diligence exercises. They refuse to provide attestation to not violating any anti-corruption laws when rendering their services for & on behalf of you.

RELATIONS WITH GOVERNMENT

Insisting on donations for sham (or otherwise) political lobbying or contributions to be made to select Goverment entities to gurantee preference on government-issued tenders. Their previous employment was with a Government entity. ​They are government-linked companies.

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Abstract Background

— Author unknown

Anecdote of 
 
the flow of
 
third party bribery 
 

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