MyComplianceOffice Blog

Approximately 90 percent of  Foreign Corrupt Practices Act (FCPA) enforcement actions involve a third party. That’s according to a recent article in the FCPA blog. The U.S. Department of Justice (DOJ) has taken notice, including an entire section on third-party risk management as part of its updated guidance for evaluating corporate compliance programs. 

Earlier this year, the National Futures Association (NFA) put forth guidance to commodity pool operators (CPOs) on the regulator’s Compliance Rule 2-9 that took effect on April 1. The guidance (aka “the Notice”) applies to CPOs with control over customer funds. It outlines what CPOS should be doing to manage employees and how they should be supervising third parties in order to meet their obligations under the new rule focused on internal controls.