Further, the Department of Justice (DOJ) is increasing the emphasis on compliance programs and holding companies to a higher overall standard. On one hand, a robust compliance program can significantly reduce penalties or help to avoid enforcement altogether with a deferred prosecution agreement (DPA) or nonprosecution agreement (NPA).
On the other hand, a company with deficient third-party risk management procedures can suffer serious harms from stiff fines, assignment of a compliance monitor and reputational damage. To build an effective, risk-based approach to managing third party relationships, a compliance program should take the 10 steps outlined in this white paper.
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