Fcpa Compliance Report

The Department of Justice Evaluation of Corporate Compliance Programs states, in Prong 10, Third Party Relationships:  Management of Relationships – How has the company considered and analyzed the third party’s incentive model against compliance risks? How has the company monitored the third parties in question? How has the company trained the relationship managers about what the compliance risks are and how to manage them? How has the company incentivized compliance and ethical behavior by third parties?  If you do not manage the relationship it can all go downhill very quickly and you might find yourself with a potential FCPA violation. Now the DOJ has explicitly adopted this approach as a key determination of whether you have operationalized your compliance program. There are several different ways that you should manage your post-contract relationship.  Relationship Manager  There should be a Relationship Manager for every third party which the company does business with through the sales chain. The Relat