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Compliance Officers Troubled By Third-Party Risk

A new FCPA study from Kroll (a sponsor of the FCPA Blog) found that the majority of corporate compliance officers at U.S. multinationals believe they’re exposed to bribery risk and fall short on best practices when it comes to third party screening, facilitating payments, and political donations.
It’s ‘the most in-depth FCPA study to-date,’ Kroll said, ‘based on detailed surveys with senior corporate compliance executives at U.S. multinationals ranging in size from $100 million to over $10 billion in annual revenues.’
Some key findings are:

  • 69% of all respondents said their companies were either moderately or highly exposed to risk related to compliance with anti-bribery laws; this number jumps to 100% in the pharmaceutical industry and drops to 46% in the financial services industry.
  • 99% percent of respondents said they had anti-bribery provisions for employees in their companies’ codes of conduct.
  • 73% have anti-bribery provisions in place for third parties. 
  • 71% require third parties to complete a disclosure listing affiliations with foreign officials (65% verify that third parties adhere to the company’s code of ethics and 73% confirm that each third party is free from sanctions pertaining to compliance with anti-bribery regulation).
  • 36% of respondents permit facilitating payments under certain circumstances; 60% do not permit facilitating payments under any circumstances.
  • 19% percent do not have a written policy with respect to facilitating payments.

The full survey is here.

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