When to Conduct Enhanced Anti-Corruption Due Diligence

Companies face significant challenges in managing their third party risk programs.  As companies improve their systems and automate their programs, they continue to face difficult situations in deciding when to conduct enhanced due diligence reviews of a potential third-party. The DOJ and SEC have provided extensive guidance in the third-party risk area, but companies have to develop and implement their own approach to deciding when to undertake intensive investigations to confirm or deny certain third party facts.