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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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Compliance Tip of the Day

Compliance Tip of the Day – Using AI to Manage 3rd Party Risk

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 look at how compliance professionals can use GenAI to help manage third-party risk and consider the MasterCard example of how GenAI can help manage massive data sets for compliance.

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

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Blog

The Future of Compliance: Leveraging AI for Real-Time Third-Party Risk Management

The rapid evolution of global commerce has brought unprecedented risks and challenges for compliance professionals. Third-party relationships, supply chain complexities, and an ever-growing web of international regulations have made traditional risk management approaches insufficient. In response, organizations are turning to artificial intelligence (AI) and blockchain to modernize their compliance programs, allowing for real-time monitoring, enhanced due diligence, and predictive analytics to identify potential violations before they escalate.

The Challenges of Traditional Third-Party Risk Management

Organizations have relied on static, manual processes to assess third-party risks for years. Compliance teams would conduct periodic vendor reviews, perform due diligence through questionnaires, and rely on external audits to verify adherence to regulations such as the FCPA and the UK Bribery Act. However, these approaches have several limitations, including the frequency of assessments, high costs and inefficiencies, lagging indicators, and lack of real-time. This can create blind spots between evaluations.

Compliance departments integrate AI-driven predictive analytics and blockchain-backed transparency into their risk management frameworks to overcome these challenges. These technologies enhance oversight in several key ways, including predictive analytics, ML for anomaly protection, automated risk scoring, immutable audit trails, and smart contracts.

Integrating AI and blockchain represents a fundamental shift in the compliance landscape. Compliance officers must adapt by developing a deeper understanding of how these technologies function and working closely with data scientists and IT teams to implement effective risk management solutions. Key actions compliance professionals should take include investing in AI training, building out cross-functional teams, establishing clear policies and procedures, and leveraging blockchain for audit readiness.

As AI and blockchain revolutionize compliance, forward-thinking organizations will be better positioned to mitigate risks, maintain regulatory adherence, and strengthen ethical business practices. The rest of this article will explore key lessons learned from AI-driven compliance programs and real-world case studies demonstrating how companies successfully leverage these technologies.

Lessons for Compliance Professionals

1. From Reactive to Proactive

Predictive compliance marks a shift from the traditional reactive approach to a proactive stance. Historically, compliance efforts focused on identifying violations after they occurred, often leading to penalties, reputational damage, and strained relationships with regulators. With AI-driven predictive compliance, organizations can assess risks before they escalate into full-blown issues.

AI systems analyze vast amounts of data, identifying early warning signs of fraud, corruption, and regulatory violations. By integrating AI into compliance programs, organizations can proactively address risks by adjusting policies, refining internal controls, and implementing mitigation strategies before incidents occur. This shift enhances compliance effectiveness and significantly reduces legal and financial risks.

Adopting predictive compliance also strengthens corporate culture. When employees and vendors know that sophisticated monitoring tools are in place, it acts as a deterrent against unethical behavior. A proactive compliance strategy fosters organizational transparency and trust, aligning ethical business practices with operational goals.

2. AI Enhances Third-Party Due Diligence

AI-powered compliance solutions allow organizations to conduct due diligence faster and more accurately than ever. Unlike traditional methods, which rely heavily on manual data collection and subjective risk assessments, AI-driven systems analyze vast amounts of structured and unstructured data to provide a comprehensive view of third-party risks. These tools leverage natural language processing (NLP) to scan regulatory filings, news reports, and legal records in real time, flagging potential issues before a formal engagement begins.

One of AI’s key advantages in due diligence is its ability to identify hidden relationships and conflicts of interest. Machine learning algorithms analyze patterns in financial transactions, vendor contracts, and social networks to detect undisclosed affiliations that could present corruption risks. This capability is particularly valuable in industries with complex supply chains, where intermediaries and subcontractors operate with minimal oversight.

Beyond efficiency gains, AI-driven due diligence reduces the likelihood of regulatory enforcement actions. Governments worldwide are tightening their scrutiny of third-party relationships, holding companies accountable for misconduct within their supply chains. By leveraging AI to conduct comprehensive and continuous due diligence, organizations can demonstrate proactive compliance efforts, mitigating the risk of fines, reputational damage, and legal liability.

3. Blockchain Creates an Immutable Compliance Trail

Blockchain technology revolutionizes compliance by providing an immutable, tamper-proof ledger recording compliance-related activities. Traditionally, companies have struggled with document integrity, audit trail manipulation, and difficulty proving due diligence efforts. Blockchain addresses these challenges by ensuring that every transaction, contract, and compliance report is permanently recorded and cannot be altered retroactively.

One of the most significant applications of blockchain in compliance is smart contracts. These self-executing agreements enforce predefined compliance rules, ensuring that all contractual obligations are met before processing payments or transactions. For example, if a supplier fails to provide necessary certifications or violates anti-bribery policies, a blockchain-based smart contract can automatically halt transactions, preventing compliance breaches before they occur.

By implementing blockchain-based compliance systems, organizations strengthen their ability to defend against regulatory scrutiny, improve operational efficiency, and foster a culture of integrity. The combination of blockchain and AI ensures that compliance processes are robust, reliable, and adaptable to future regulatory developments.

4. AI and Blockchain Reduce Fraud and Corruption Risks

Fraud and corruption remain two of the biggest threats to global business, with organizations losing billions annually due to unethical practices. AI and blockchain technologies provide companies with the tools to significantly reduce these risks by enhancing detection, prevention, and accountability.

AI’s ability to detect fraud is based on pattern recognition. Machine learning models analyze large volumes of transactional and behavioral data to identify irregularities that may indicate fraudulent activity. For example, AI-driven systems can spot anomalous payment flows, shell companies, or repeated transactions that resemble known bribery schemes. Unlike traditional fraud detection methods that rely on predefined rules, AI continuously learns from new data, improving its ability to identify suspicious activity over time.

Companies can create a robust fraud prevention framework by combining AI’s predictive capabilities with blockchain’s verifiable record-keeping. Organizations can use AI to monitor ongoing transactions for potential fraud while relying on blockchain to maintain a tamper-proof record of financial activities. This dual-layer approach reduces fraud risk and enhances compliance with anti-bribery and anti-money laundering regulations.

Furthermore, regulatory agencies are taking notice of these technological advancements. Government bodies now expect businesses to incorporate AI and blockchain into compliance programs to ensure transparency and accountability. Companies that fail to adopt these technologies risk falling behind in regulatory expectations, increasing their exposure to legal and reputational damage.

5. AI Helps Identify Emerging Geopolitical Risks

In the chaos of 2025, businesses are exposed to a wide range of geopolitical risks, including trade restrictions, sanctions, political instability, and shifting regulatory environments. America’s business friend today could well be America’s geopolitical enemy tomorrow. Traditional compliance models often struggle to keep pace with these rapidly evolving risks, leaving organizations vulnerable to financial losses, legal repercussions, and reputational damage.

AI-powered risk assessment tools provide a proactive solution by continuously monitoring and analyzing geopolitical developments in real-time. Machine learning algorithms process vast amounts of data from news reports, government announcements, market trends, and regulatory updates to identify emerging risks before they impact business operations. By leveraging AI, compliance teams can anticipate geopolitical threats and adjust their risk management strategies accordingly.

AI-driven systems can detect changes in trade policies, predict potential sanctions on high-risk jurisdictions, and flag supply chain vulnerabilities stemming from political unrest. Compliance teams can use these insights to take preemptive actions, such as adjusting procurement strategies, diversifying supply chain partners, or reinforcing due diligence on vendors operating in volatile regions.

Moreover, AI helps organizations navigate complex international regulations by mapping regulatory changes across multiple jurisdictions. Instead of manually tracking compliance requirements for each country, businesses can rely on AI to automate regulatory updates and ensure continuous adherence to legal standards worldwide.

By integrating AI into compliance programs, organizations can transform geopolitical risk management from a reactive process into a proactive strategy. This reduces regulatory exposure and enhances business resilience in an increasingly uncertain global landscape.

The Future is Now: Mastercard – AI in Fraud Detection and Compliance Risk Assessment

The future of compliance is unfolding now, and Mastercard’s recent success offers a compelling glimpse into this new era.

With billions of daily transactions and ever-evolving financial crime methods, Mastercard recognized the limitations of conventional fraud detection systems. The company embraced artificial intelligence (AI) for real-time transaction analysis, significantly transforming its compliance landscape. Mastercard’s AI-driven system scrutinizes vast datasets instantaneously, pinpointing irregular spending behaviors and high-risk cross-border activities that traditional methods might miss. The implementation resulted in remarkable outcomes—a 40% improvement in fraud detection rates, significantly reduced regulatory compliance violations, and notably strengthened customer trust and transactional security.

This example underscores the pivotal shift compliance departments must embrace, transitioning from reactive to proactive strategies through technology. AI, complemented by blockchain, equips organizations to anticipate and neutralize risks in real-time, delivering predictive analytics, enhanced due diligence, and immutable records for rigorous compliance assurance. Compliance professionals must understand and actively engage with these technologies, collaborating cross-functionally to embed AI-driven systems within organizational risk management frameworks.

The Mastercard case illustrates how strategic technology investments translate into tangible compliance benefits, positioning businesses to mitigate emerging risks effectively and uphold ethical standards. The future is now, and embracing AI and blockchain is no longer optional—it’s essential for modern compliance effectiveness.

The compliance landscape is fundamentally transforming, driven by the rapid evolution of global commerce and intensifying regulatory scrutiny. Traditional methods of third-party risk management—periodic manual assessments and retrospective audits—are increasingly proving inadequate in addressing the complexity and speed of today’s compliance environment. Organizations are now turning to cutting-edge technologies like artificial intelligence (AI) and blockchain, embracing predictive analytics, real-time monitoring, and enhanced transparency to proactively identify and mitigate risks before they escalate into full-blown compliance issues.

This shift from reactive to proactive compliance improves risk management effectiveness and significantly reduces financial and legal exposure. AI-powered systems enable compliance teams to conduct comprehensive due diligence, uncover hidden relationships and conflicts, and dynamically adapt to emerging geopolitical threats. Meanwhile, blockchain technologies provide immutable audit trails and smart contracts that automate compliance processes, reducing fraud, corruption, and audit trail manipulation. Mastercard’s successful deployment of AI-driven fraud detection highlights the potential of these technologies, demonstrating substantial improvements in detection rates, reduced regulatory violations, and increased customer trust. For compliance professionals, the imperative is clear—embracing AI and blockchain technologies is not merely beneficial; it’s essential for navigating the complexities and risks inherent in modern business.

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FCPA Compliance Report

FCPA Compliance Report: Jag Lamba on Integrating AI with Existing Compliance Systems

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, Tom Fox welcomes back Jag Lamba from Certa AI, the sponsor of this podcast, to consider the integration of AI into your overall compliance framework.

Our discussion emphasizes the importance of using great software to effectively integrate AI into existing processes, systems, and teams. For successful implementation, the software should be both flexible and scalable to suit different organizational needs and volumes. Moreover, the incorporation of guardrails is crucial in areas like third-party compliance due to AI being a relatively new technology. These guardrails function as a framework to prevent excessive autonomy, similar to the limitations set on a new coworker. It is fascinating to look at the cutting-edge use of AI in compliance.

 

Highlights in this Episode:

  • Integrating AI with Existing Systems
  • The Human in the Loop
  • Flexibility and Scalability in Software
  • Key Elements: Guardrails in AI

Resources:

Jag Lamba on LinkedIn

Certa.AI

Tom Fox

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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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Innovation in Compliance

Leveraging Technology in Third-Party Risk Management with Jag Lamba and Jared Ezzell

Jag Lamba and Jared Ezzell from Certa, join Tom Fox on the Innovation In Compliance podcast to explore the essential elements of a thriving third-party risk management program. They emphasize the significance of minimizing reliance on third-party self-disclosures by utilizing technology and data. They also highlight the importance of integrating due diligence, training, and ongoing monitoring to create a comprehensive approach to risk management. The conversation extends to payment controls, charitable donations, and the integration of the program into the overall third-party risk management lifecycle. 

Jag is the founder and CEO of Certa. Jared Ezzell is the Chief Customer Officer. Certa is a third-party lifecycle management platform for procurement, compliance, and ESG. Their no-code platform provides an easy and efficient way to digitize and manage the lifecycle of all suppliers, partners, and customers. Certa’s automated onboarding, contract lifecycle management, and ESG management eliminate the procurement bottleneck, allowing companies to onboard third parties three times faster. With their cutting-edge technology, Certa is transforming the way businesses manage their third-party relationships, ensuring compliance and sustainability at every step.

 

Here are some key points Tom, Jag, and Jared talk about:

  • Jared talks about his professional background and his role at the company Certa, their products, and their customers. 
  • The hallmark of an effective anti-bribery and anti-corruption compliance program is the concept of risk assessment.
  • Jared discusses the nine elements developed by Certa for an effective compliance program.
  • The three dimensions of a complete solution for compliance risk management are full spectrum risk management, the full life cycle of the third party, and the full spectrum of third parties.
  • A successful technology transformation project should be a modular rollout, with a focus on solving the highest pain point within three months and continuously phasing the rollout to avoid becoming overwhelmed.
  • Jag and Jared clarify that while the company doesn’t play the role of creating the documentation, they provide input and help evidence the client’s defensible positioning in support of the client’s policies.
  • Jag tells Tom that the ongoing monitoring of third-party relationships requires companies to have data sources and processes in place, have a controls framework to act on information, and automate controls to handle egregious alerts.

 

KEY QUOTE:

“The ability to systematically enforce payment controls is a key common practice in successful third-party risk management.” – Jared Ezzell

 

Resources:

Jag Lamba on LinkedIn | Twitter 

Jared Ezzell on LinkedIn 

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Corruption, Crime and Compliance

Episode 235 – Third-Party Risk Management


The global economy has suffered two significant shocks — first, the pandemic sent shockwaves through every organization, and second, the war in Ukraine. Both of these events exposed the importance of risk management, especially with regard to supply chain and distribution operations. Hence, the renewed focus on third-party risk management and the repetitive description of “holistic” third-party risk management. Reality forces change, and we are now experiencing significant adjustments to overall risk management procedures. At the top of every list has to be third-party risk management beyond legal and compliance risks — we have new disruptive risks that have to be identified, quantified, or ranked and then addressed.
Michael Volkov outlines the new reality and opportunities stemming from holistic third-party risk management in this episode.

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Innovation in Compliance

Exiger on the Evolution in Supplier Compliance in COVID – Third-Party Party Risk Management Solutions with Erika Peters and Skyler Chi


Welcome to the fifth and final episode of a special five-part podcast series, sponsored by Exiger, on topics From Third-Party Risk Management to Supply Chain Risk Management: Exiger on the Evolution in Supplier Compliance in COVID. Exiger was founded to fight financial crime, fraud and terrorist financing by introducing technology-enabled solutions to the market’s biggest supply chain, risk, investigation, litigation, and compliance challenges. A global authority on risk and compliance, Exiger serves the world’s largest banks, Fortune 1000 companies and government agencies and regulators. Over the past five episodes, we have put a spotlight on Financial Institutions with Tara Loftus and Samar Pratt; focus on corporations with Aaron Narva and George ‘Ren’ McEachern; consider the Federal Government and Supply Chains with Carrie Wibben and Vishnu Anantatmula; review the pillars of good compliance with Brandon Daniels and Carrie Wibben; and end with a review of third-party risk management solutions with Erika Peters and Skyler Chi.
Today, Part 5, we conclude with a review of third-party risk management solutions with Erika Peters and Skyler Chi. Peters is an Associate Managing Director based in Exiger’s New York office, where she focuses on the firm’s financial crime compliance and assurance practices. Chi is an Associate Director based in Exiger’s New York office. With nearly ten years of forensic accounting and investigative experience he leverages world-class technology (e.g., SQL, Python, Tableau, natural language processing and machine learning) in order to aid in financial investigations and government clients in bank/investment statement reviews and analyses, data analysis efforts, large document analyses, and extensive e-mail reviews.
For more information on Exiger, click here.
For more information on Erika Peters, click here.