Third-Party Management: A Risk-Based Approach - Part 5: Alexander Cotoia on Use Cases
Thomas Fox
The Voice of Compliance*Founder of The Compliance Podcast Network*Evangelizing for and Serving the Compliance Community
Welcome to a special 5-part podcast series sponsored by Diligent. Over this series, I will visit with Michael Parker, the Director of Advisory and Consulting Services; Stephanie Font, Director of the Optimizations Group; Kairi Isse, Managed Services Group Manager; Adam Bailey, Senior Vice President, Product Management and Alexander Cotoia, from the Volkov Law Group.
In this Part 5, I visit with Alexander Cotoia, a Regulatory and Compliance Manager at the Volkov Law Group to consider how recent FCPA enforcement actions point toward the use cases for a robust third-party risk management system.
In 2022, the overwhelming majority of FCPA-related enforcement actions involved third parties and required organizations to reprioritize third-party risk management. In this episode, we consider case studies involving ABB Limited, GOL Airlines, and Oracle which all demonstrated the importance of understanding bribery and corruption schemes, making voluntary disclosures, and reassessing third-party risk management.
Key Highlights:
From the Foreign Corruption Practices Act (FCPA) enforcement actions in 2022, one clear theme emerges: organizations must reprioritize their third-party risk management programs. Many companies are becoming complacent in this arena, not realizing the potential consequences of not properly assessing their third-party risk management practices. I recently had the opportunity to visit with Alexander Cotoia of the Volkov Law Group to discuss the importance of reprioritizing third-party risk management and how organizations can assess the effectiveness of their current practices. We review three 2022 FCPA enforcement actions to explore the importance of proper third-party risk management and how to avoid the potential consequences of not properly assessing these risks. Join us as we explore the details and implications of these enforcement actions and how organizations can reprioritize their compliance programs for the ever-changing dynamics of third-party risk management.
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With recent announcements of increasingly stringent federal policies around record-keeping and due diligence, compliance, and investigation, professionals are feeling the pressure to demonstrate consistency and rigor in their case management processes.
Planning your investigation, having the right team members involved, and reporting on the outcomes of an investigation can all be difficult phases of the process.
However, being able to demonstrate that you are quickly, consistently, and accurately triaging incidents is even more important now.
The key is establishing decision-making approaches and planning out your entire protocol before the matter comes to your attention through hotline reporting or other mechanisms. This ensures structure and success as you triage, investigate, staff the investigation properly, and meet the inevitable challenges of reporting and addressing the root causes of incidents.
Join compliance expert Tom Fox on March 28th at 2 PM ET as he explores these topics and more.
This webinar will provide a guide to key triage best practices, including
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