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Predictive. Proactive. Protected: Leveraging AI for Real-Time Third-Party Risk Management

Even in 2025, third-party risk management remains one of the thorniest challenges for compliance professionals. Whether you oversee distributors in the Middle East, suppliers in Southeast Asia, or data processors in Eastern Europe, the risks, including bribery, sanctions violations, labor abuses, and fraud, remain ever-present. Traditionally, compliance teams fought these battles using static tools: onboarding questionnaires, annual reviews, and spreadsheet trackers. But those blunt instruments are no longer enough in today’s real-time risk environment.

Enter AI, specifically Generative AI (GenAI), predictive analytics, and blockchain, which is revolutionizing third-party oversight and giving compliance professionals the power to act proactively, not reactively. As Jag Lamba, CEO of Certa, astutely notes, GenAI brings three significant value buckets: reduced risk, commercial ROI, and reduced legal costs. Today, I will unpack what that means for compliance and how we can move from the “check-the-box” era to one of integrated, continuous monitoring and risk mitigation.

Compliance in Real Time: The Shift to Predictive Tools

Historically, the compliance approach to third-party risk was episodic. We conducted due diligence at onboarding, maybe revisited it every few years, and crossed our fingers in between. However, the gaps between assessments were dangerous blind spots, exposing companies to risks that regulators like the DOJ and SFO are increasingly unwilling to tolerate.

That’s where predictive analytics steps in. To forecast potential violations, these systems analyze structured and unstructured data, from financial records to adverse media to geopolitical trends. AI flags early risk indicators, such as an unusual payment pattern or a politically exposed person. That allows compliance to intervene before a deal closes, a bribe is paid, and reputational damage is done.

Machine learning (ML) models also allow dynamic anomaly detection. This is especially useful in sifting through transactional data and flagging high-risk behavior patterns like duplicate invoices, mismatched documentation, or sudden changes in third-party ownership.

Blockchain brings an additional layer of trust. Immutable audit trails secure contracts, payments, and due diligence documentation, ensuring the record is tamper-proof and regulator-ready. Smart contracts can enforce compliance obligations automatically, stopping payments, triggering alerts, or suspending activity when a vendor falls out of bounds.

Three Buckets of Value: What GenAI Delivers

Jag Lamba, CEO of Certa, outlined three distinct areas where GenAI delivers:

  1. Risk Reduction Compliance risk, data privacy risk, ESG risk, reputational risk—the list goes on. AI helps companies avoid working with third parties that introduce these risks into the business ecosystem. This is more than good practice; it is a lifeline for organizations operating under Deferred Prosecution Agreements (DPAs) or with heightened scrutiny from regulators.
  2. Commercial Value Faster onboarding of sales agents, vendors, or channel partners means faster revenue. Reducing a six-week onboarding timeline to two days can translate into hundreds of millions in new revenue, especially in fast-moving sectors.
  3. Legal Savings Avoiding regulatory missteps means avoiding costly enforcement actions. In today’s aggressive enforcement climate, those savings are not simply theoretical; they are very real and very substantial.

Compliance should not be a handbrake on business; it should be a business enabler. By embedding GenAI into core operations, organizations create less friction and fewer dual processes, improving business agility without sacrificing oversight.

Five Takeaways for Compliance Professionals

  • Predictive Compliance Is the New Norm

The days of “wait and see” are over. AI lets us anticipate risk, not just react to it. Predictive tools shift compliance from being an internal auditor to a strategic partner in risk mitigation. Companies like Certa use automated third-party master data enrichment to reduce false positives and streamline screening, creating cleaner data for faster, smarter decisions.

  • AI Supercharges Due Diligence

Natural language processing (NLP) and machine learning enable deep due diligence at scale. To flag red flags, AI can scan global watchlists, sanctions databases, court records, and newsfeeds. It can uncover hidden connections, shell entities, familial relationships, and obscure affiliates that human reviewers often miss.

Even better, AI does not sleep. It continually updates third-party risk profiles in real time, offering dynamic monitoring that aligns with today’s fast-changing regulatory landscape.

  • Real-Time Supply Chain Monitoring Is a Must

Supply chains are now under a microscope. From human rights to trade sanctions, regulators demand evidence that companies are proactively managing supply chain risks. AI tools monitor supplier behaviors and flag real-time ESG risks, such as forced labor or environmental non-compliance.

Blockchain ensures that supply chain data remains unaltered and provides traceability across multiple tiers of suppliers. With AI-integrated blockchain systems, compliance professionals can quickly identify issues, trace them to their source, and take corrective action.

  • AI + Blockchain = Fraud and Corruption Prevention

Fraud detection meant following static rules, like transaction thresholds or vendor location mismatches. AI adds nuance. It can detect bribery patterns or fraudulent shell entities by learning from thousands of real-world cases. Meanwhile, blockchain creates an unchangeable record of each transaction, making it harder for corrupt actors to falsify invoices or backdate payments. This two-pronged approach, predictive analytics plus immutable records, offers a potent defense against FCPA and UKBA violations.

  • Third-Party Risk Must Be Continuous, Not Episodic

Third-party due diligence cannot be a one-and-done exercise. Predictive analytics enables a live risk-scoring environment where third parties are constantly evaluated. AI can even detect patterns that suggest “compliance-sensitive” activity, like vendors interacting with government officials or operating in high-risk jurisdictions, flagging them for further review.

One multinational recently implemented a no-code solution that monitors purchase requisitions for signs of regulatory engagement, triggering automated validation questions. This kind of innovation is only possible when compliance works in tandem with IT, legal, and procurement.

Compliance at a Crossroads: Innovate or Fall Behind

After the Trump Administration’s Executive Order suspending FCPA investigation and enforcement, compliance professionals face a fundamental choice: evolve or be eclipsed. But in 2025, manual reviews and siloed spreadsheets. Business leaders expect real-time monitoring, cross-functional integration, and data-backed decision-making to create greater business value. That means compliance must step into a new leadership role that embraces technology, champions cross-department collaboration, and drives value across the enterprise.

It is time for compliance teams to stop seeing AI as a future concept and start seeing it as a present-day imperative. The organizations that embrace this shift will thrive in the next wave of regulatory scrutiny and be best equipped to meet the moment.

As the saying goes, “The best way to predict the future is to invent it.” For compliance professionals, that future is AI-driven, real-time, and risk-resilient.

This article was based on my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com.

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31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 21 – Managing 3rd Parties

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.

On Day 21 of our series, we dive into the essential strategies for managing third-party relationships in a compliance program. We consider the significance of a structured and strategic approach in handling third parties to mitigate anti-corruption risks. As companies mature, the operationalization of compliance through third-party management becomes crucial. Key areas explored include the importance of dual and diversified sourcing, monitoring subcontractors, legal protections, and financial stability checks. Additionally, we cover the necessity of integrating performance-based compensation and regular auditing to uphold compliance standards. Join us tomorrow as we explore levels of due diligence on Day 22.

Key highlights:

  • Strategic Approach to Third-Party Relationships
  • Auditing and Ongoing Management
  • Key Takeaways

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 5th edition, by clicking here.

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Compliance Tip of the Day

Compliance Tip of the Day – Board Questions and Metrics for 3rd Party Risk Management

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements. Whether you’re a seasoned compliance professional or just starting your journey, we aim to provide bite-sized, actionable tips to help you stay on top of your compliance game. Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law. Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

Today, we consider what questions a Board of Directors should ask a CCO and the types of metrics they should ask for in their role of overseeing the compliance program.

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

Check out the full 3-book series, The Compliance Kids, on Amazon.com.

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FCPA Compliance Report

FCPA Compliance Report: Evie Wentink on Making Compliance Training Practical

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance.

In this edition of the FCPA Compliance Report,  Tom Fox has a fascinating visit with Iveta (Evie) Wentink, a 15-year compliance veteran. Evie has worked in the public and private sectors and has expertise in compliance training, hotlines, government contract compliance, data privacy, reporting, & due diligence.

Evie has one of the most unique opening lines for hotline training, which is ‘Do You Know Your Hotline Number?” This simple yet incredibly important question encapsulates Evie’s approach to compliance training: make it simple, direct, and practical for the listeners. (Or, as Carsten Tams would say, ‘It’s all about the UX’).

Our conversation focuses on the critical role of hotline numbers in corporate compliance programs, emphasizing the need for employees to know and trust the hotline. Evie shares insights from her career, highlights the significance of marketing compliance hotlines effectively, and discusses the broader culture of compliance and non-retaliation in organizations. She shares practical tips for improving hotline awareness and usage, making this episode a valuable resource for compliance professionals and organizations alike.

Highlights in this Episode:

  • Enhancing Trust through Active Compliance Reporting
  • Promoting Reporting Culture Through Creative Marketing
  • Ethical Culture: Encouraging Compliance Reporting Safely
  • Enhancing Compliance Programs Through Anonymous Hotlines

Resources:

Evie Wentink on LinkedIn

Evie’s Top 10 Compliance Back to Basics

Tom Fox

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For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

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Compliance Into the Weeds

Compliance into the Weeds: Sustainability and Managing 3rd Party Risk

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject.

Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode, Tom Fox and Matt Kelly take a deep dive into a recent report by Prevalent on Third Party Risk Management in 2024 and Microsoft’s 2024 Environmental Sustainability Report.

Tom and Matt discuss the challenge companies face in aligning their sustainability goals with their supply chain management. They question whether sustainability functions within a company have the authority to influence supply chain decisions, such as rejecting suppliers that do not meet sustainability criteria.

We discuss the  Microsoft Report, noting that while the company acknowledges it has not yet achieved the ability to reject non-compliant suppliers, it suggests a target of improvement by 2030. The core issue highlighted is whether sustainability initiatives will have significant influence over supply chain decisions in the future. 

Key Highlights:

  • Intersection of Supply Chain Risk Management and Sustainability
  • The Role of Sustainability in Supply Chain Decisions
  • Microsoft’s Journey Towards Sustainable Supply Chain Management
  • The Energy Industry Model

Resources:

Matt on Radical Compliance

Tom 

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Compliance Week Conference Podcast

Compliance Week 2024 Speaker Preview Podcasts – Rodney Campbell on Managing 3rd Parties

In this episode of the Compliance Week 2024 Speaker Preview Podcasts series, Rodney Campbell discusses his presentation at Compliance Week 2024, “Empowering TPRM Compliance: Transformative Strategies in Third-Party Risk Management.” Some of the issues he will discuss in this podcast and his presentation are:

  • Why managing third parties is a critical element in your TPRM program
  • Leveraging your business unit to help manage third parties
  • New ideas for the compliance program from Compliance Week 2024

I hope you can join me at Compliance Week 2024. This year’s event will be held April 2-4 at The Westin Washington, DC, Downtown. The line-up for this year’s event is first-rate, with some of the top ethics and compliance practitioners around.

Gain insights and make connections at the industry’s premier cross-industry national compliance event, offering knowledge-packed, accredited sessions and take-home advice from the most influential leaders in the compliance community. Back for its 19th year, join 500+ compliance, ethics, legal, and audit professionals who gather to benchmark best practices and gain the latest tactics and strategies to enhance their compliance programs. Compliance, ethics, legal, and audit professionals will gather safely face-to-face to benchmark best practices and gain the latest tactics and strategies to enhance their compliance programs, among many others, to:

  • Network with your peers, including C-suite executives, legal professionals, HR leaders, and ethics and compliance visionaries.
  • Hear from 80+ respected cross-industry practitioners who are CEOs, CCOs, regulators, federal officials, and practitioners to help inform and shape the strategic direction of your enterprise risk management program.
  • Hear directly from panels on leadership, fraud detection, confronting regulatory change, abiding by cross-border rules and regulations, and the always-favorite fireside chats.
  • Bring actionable takeaways to your program from various session types, including cyber, AI, Compliance, Board obligations, data-driven compliance, and many others, for you to listen, learn, and share.
  • Compliance Week aims to arm you with information, strategy, and tactics to transform your organization and career by connecting ethics to business performance through process augmentation and data visualization.

I hope you can join me at the event. For information on the event, click here. As an extra benefit to listeners of this podcast, Compliance Week is offering a $200 discount on the registration price. Enter the discount code TFOX2024 for $200 off.

The Compliance Week 2024 Preview Podcast series is a production of the Compliance Podcast Network. Compliance Week is the sponsor of this series.

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31 Days to More Effective Compliance Programs

One Month to More Effective Written Standards: Day 17 – Policies for Third-Parties

As every compliance practitioner is well aware, third-parties still present the highest risk under the FCPA. The DOJ 2023 ECCP devotes an entire prong to third-party management. It begins with the following: A well-designed compliance program should apply risk-based due diligence to its third-party relationships.  Although the degree of appropriate due diligence may vary based on the size and nature of the company or transaction, prosecutors should assess the extent to which the company has an understanding of the qualifications and associations of third-party partners, including the agents, consultants, and distributors that are commonly used to conceal misconduct, such as the payment of bribes to foreign officials in international business transactions.
This set of queries clearly specifies the DOJ expects an integrated approach that is operationalized throughout the company. This means your compliance program must have a process for the full life cycle of third-party risk management. There are five steps in the life cycle of third-party management: 1) business justification; 2) questionnaire to third-party; 3) due diligence on third-party; 4) compliance terms and conditions, including payment terms; and 5) management and oversight of third parties after contract signing.
I continually give my mantra of compliance, which is “Document, Document, and Document”. Each of the steps you take in the management of your third parties must be documented. Not only must they be documented but they must be stored and managed in a manner that you can retrieve them with relative ease. The management of third parties is absolutely critical in any best practices compliance program.

Three key takeaways:

  1. Use the full five-step process for third-party management.
  2. Make sure you have Business Development involvement and buy-in.
  3. Operationalize all steps going forward by including business unit representatives.

For more information, check out The Compliance Handbook, 4th edition, here.

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Blog

Building a Stronger Culture of Compliance Through Targeted and Effective Training: Part 4-A Training Program for 3rd Parties

Welcome to a special 5 part blog post series on building a stronger culture of compliance through targeted and effective training, sponsored by Diligent. Over this series I will visit with Kunal Agrawal, Director of Customer Success at Diligent; Kevin McCoy, Customer Success Manager at Diligent; Jessica Czeczuga, a Principal Instructional Designer; Andrew Rincon, Global Accounts Management Advisor at Diligent; and David Greenberg, former CEO and Special Advisor at LRN and Director at International Seaways. Over this series, we will consider the importance of ongoing communications, the value of targeted training, training third-parties, and the role of the Board of Directors. In this Part 4, we discuss how to put together a training program for third parties with Andrew Rincon.

In today’s global business landscape, third-party compliance training are more crucial than ever. Ensuring that your organization’s distributors, vendors, and other third-party affiliates adhere to necessary regulations can minimize legal and financial risks, protect your company’s reputation, and foster a culture of ethical business practices. As compliance professionals responsible for training these third parties, it’s essential to stay informed about cutting-edge strategies and techniques for effective risk management. This blog will explore practical steps that can be implemented to improve your third-party compliance training and due diligence processes, allowing you to uphold your organization’s regulatory standards and contribute positively to the industry. Here are the steps to get Improved third-party compliance training and due diligence processes.:

1. Assess third-party risk during onboarding.

2. Utilize micro training videos for efficiency.

3. Customize training materials for specific regions.

Assess third-party risk during onboarding. Due Diligence on and assessing third-party risk is not a ‘one size fits all’ process. This critical step allows organizations to identify high-risk distributors, vendors, and other third parties that may pose potential threats to the business in terms of bribery, corruption, and other regulatory violations. By conducting a thorough risk assessment, organizations can effectively mitigate these risks and ensure that they are partnering with ethical and responsible businesses, ultimately fostering a strong culture of compliance throughout their sales or supply chain ecosystem. Moreover, such an approach is critical throughout the lifecycle of the relationship. Rincon emphasized the importance of proactive ongoing due diligence measures, such as automated screenings and monitoring, sending out attestations, and conducting regular training courses.

Effectively educating, resellers, agents distributors and other third-parties on compliance policies and expectations is critical and cannot be overstated. Providing proactive training not only helps in preventing compliance violations but also demonstrates to regulators your organization’s commitment to maintaining high ethical standards. This, in turn, can mitigate penalties in case of inadvertent violations and foster a trust-based relationship with regulatory authorities. By adopting these practices and leveraging technology to automate certain processes, organizations can ensure that they are partnering with ethical third parties, minimize their exposure to regulatory risks, and foster a strong culture of compliance across their entire network. By doing so, they not only protect their businesses from potential harm but also contribute to a more transparent and ethical global marketplace.

Utilize micro training videos for efficiency. In the field of compliance, training third parties remains a critical aspect of managing and mitigating risks associated with regulatory and legal frameworks such as the Foreign Corrupt Practices Act (FCPA). With the increasing need for efficient and effective compliance processes, it becomes essential for compliance professionals to employ innovative strategies to achieve their objectives while minimizing disruptions to business operations. By leveraging this method, companies can ensure that their distributers and internal client gatekeepers receive consistent and easily digestible information, enhancing their understanding of compliance policies and expectations.

Rincon said that by breaking down complex topics into easily understandable portions, micro training videos enable organizations to communicate the essential aspects of their compliance policies and expectations in a concise and engaging manner. Through the ability to cater to different audiences, these training resources contribute to a more comprehensive approach towards addressing third-party risk. The adoption of micro training videos as a tool for third-party compliance education serves an essential purpose for compliance professionals. By incorporating this method, companies can enhance their third-party risk management processes and ensure that their partners are aware of the applicable legal and regulatory frameworks. This leads to improved adherence to compliance policies, reduced likelihood of violations, and overall risk mitigation.

Customize training materials for specific regions. Effective third-party compliance training often involve the customization of training materials for specific regions. This ensures that the training is relevant, relatable, and impactful for third parties, taking into account regional differences, languages, and sensibilities. Customizing training materials also fosters a deeper and more nuanced understanding of the compliance policies and expectations towards each party, thereby mitigating the risks associated with inadequate understanding or implementation of compliance standards. Furthermore, cultural sensitivities and regional variations can be taken into account when designing training, ensuring a more engaging and effective learning experience for the target audience.

Rincon micro-training video shorts can be easily customized for different regions and translated into multiple languages. With such versatile tools, compliance professionals can promote clear and concise messaging to their third-party partners, thus reinforcing the importance of compliance policies and due diligence throughout the duration of the business relationship. Customizing compliance training materials for specific regions not only makes the training more effective, engaging and relevant but also supports robust risk management and streamlined third-party due diligence processes.

For compliance professionals dedicated to training third parties, the effectiveness of your compliance and due diligence processes plays a significant role in safeguarding your organization from potential risks. The steps discussed, including customizing training materials for specific regions, agents, reseller, distributors and other business parnters on compliance policies and using technology to track irregularities, can greatly enhance your efforts to ensure that your third parties meet and maintain compliance expectations. With diligent application of the guidance provided, you can foster a well-informed and compliant network of third parties, ultimately ensuring your organization’s ongoing success.

For more information go to http://diligent.com/compliancetraining.

Join us tomorrow where we review the role of the Board of Directors in a compliance regime.

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Innovation in Compliance

Building a Stronger Culture of Compliance Through Targeted and Effective Training: Part 4 – A Training Program for 3rd Parties

Welcome to a special 5 part podcast series on building a stronger culture of compliance through targeted and effective training, sponsored by Diligent. Over this series, I will visit with Kunal Agrawal, Director of Customer Success at Diligent; Kevin McCoy, Customer Success Manager at Diligent; Jessica Czeczuga, Director, Compliance and Ethics at Diligent; Andrew Rincón, Client Director at Diligent; and David Greenberg, former CEO and Special Advisor at LRN and Director at International Seaways. Over this series, we will consider the importance of ongoing communications, the value of targeted training, training third parties, and the role of the Board of Directors. In this Part 4, we discuss how to put together a training program for third parties with Andrew Rincón.

Join Tom Fox in an exciting episode about building a stronger culture of compliance through targeted and effective training as he interviews Andrew Rincón. Discover how the compliance industry has evolved and how technology has significantly improved compliance programs. Find out how efficient compliance processes create goodwill for compliance professionals and make them true partners of the business with the help of technology and reliable due diligence partners. Andrew Rincón shares Diligent’s screening and monitoring options for third-party suppliers and the customized anti-bribery and anti-corruption training, available in multiple languages, also perfect for bite-sized, animated micro-learnings. Tune in to learn how to educate distributors and internal gatekeepers on compliance and useful resources for compliance professionals, only on a training program for 3rd parties.

Highlights Include:

  • The Role of Compliance with Distributors
  • Efficient Due Diligence for Distributors
  • Diligent’s Anti-Bribery and Sanctions Screening Solutions
  • Compliance Training & Internal Controls for Distributors
Notable Quotes

“And commission sales agents are certainly recognized as, if not the highest, a high risk, under the FCPA and other compliance regimes.”

“One area the thinking has evolved on, and it sounds like your career and my career, is that due diligence alone is insufficient.”

“So being as efficient as a process. And nowadays, everything moves at the speed of light.”

“But nowadays, with the amount of information that gets published every single day throughout the world, where there’s so much content out there.”

For more information, go to Diligent.com

Join us tomorrow as we conclude our series with a look at the role of the Board of Directors in a compliance program.

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FCPA Compliance Report

FCPA Compliance Report – Brad Hibbert on Prevalent’s 2023 3rd Party Risk Management Report

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Today, Tom visits Brad Hibbert, COO/CSO at Prevalent, as they discuss the surprising findings of Prevalent’s annual third-party risk management study. Discover why so many organizations still rely on spreadsheets and manual processes for managing third-party risks. Brad recommends an integrated approach to third-party risk management that considers the entire lifecycle of the relationship with third parties.

The podcast highlights the top five key findings of the report, including data breaches as the top concern, security driving the program, and the increased involvement of IT in the process. Learn how to minimize cyber exposure and risks associated with third-party management by breaking down silos, automating processes, and focusing on reducing risks associated with third parties. Listen to Brad’s practical advice on how to prioritize risks and plan your risk management program and visit prevalent.net for more compliance mandates and best practices. With exciting insights and actionable advice, this podcast is a must-listen for anyone interested in managing third-party risks.

Key Highlights:

·      Prevalent’s annual third-party risk management study

·      Integrated Third Party Risk Management

·      Top Challenges for Organizations in Data Security

·      Third Party Risk Management Survey and Findings

·      Minimizing Cyber Breaches

·      Effective Response to Breaches and Third-Party Programs

·      Managing Business Risks for Compliance

Notable Quotes:

“The top concern driving third-party risk management programs is security, with 71 percent indicating it as their main priority.”

“Data breaches continue to be a top concern, with 41 percent of the respondents indicating that they were impacted by a third-party data breach in the last 12 months and had to perform some remedial activity.”

“About 70 percent reported increased involvement from the IT group, while 71 percent indicated that infosec owns the program.”

“Identifying and mitigating risks before the company is impacted.”

“Customs put together this enforcement dashboard that contains all of these statistics on how they’ve been enforcing the UFLPA.”

Resources

Brad Hibbert on LinkedIn

Prevalent

3Rd Party Risk Management Report

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