Fcpa Compliance Report

There are five steps in the life cycle of third party management. Business Justification and Business Sponsor; Questionnaire to Third Party; Due Diligence on Third Party; Compliance Terms and Conditions, including payment terms; and Management and Oversight of Third Parties After Contract Signing.   Step 1 - Business Justification  The first step breaks down into two parts:  Business Sponsor Business Justification  The purpose of the Business Justification is to document the satisfactoriness of the business case to retain a third party. The Business Justification should be included in the compliance review file assembled on every third party at the time of initial certification and again if the third party relationship is renewed.   Step 2 - Questionnaire  The term ‘questionnaire’ is mentioned several times in the FCPA Guidance. It is generally recognized as one of the tools that a company should complete in its investigation to better understand with whom it is doing business. I believe that this require