ST1155
A well-designed compliance program should apply risk-based due diligence to its third-party relationships. Although the need for, and degree of, appropriate due diligence may vary based on the size and nature of the company, transaction, and third party, prosecutors should assess the extent to…
Plain-language summary
What it actually means.
Plain-language summary forthcoming. Source text below.
Source text
As written.
A well-designed compliance program should apply risk-based due diligence to its third-party relationships. Although the need for, and degree of, appropriate due diligence may vary based on the size and nature of the company, transaction, and third party, 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.
Assessed by HEXDI
What HEXDI assesses.
- M2
6 — PROGRAM SETUP AND ADMINISTRATION
Risk analysis and identification considers risks posed by interactions with third parties, to include suppliers, brokers, contractors,…
- M9
2 — THIRD PARTY MANAGEMENT
Program requires maintenance of a vendor database.
- M9
3 — THIRD PARTY MANAGEMENT
Program has procedures to ensure that the vendor database is kept current.
- M9
1 — THIRD PARTY MANAGEMENT
Program requires prohibited party screening of all vendors, to include screens of the vendor’s name, address, associated persons, and…
- M9
2 — THIRD PARTY MANAGEMENT
Program requires reasonable due diligence screening of distributors, freight forwarders, customs brokers, foreign sales representatives,…
- M9
3 — THIRD PARTY MANAGEMENT
Program requires the use of freight forwarders and customs brokers that are properly vetted to ensure they are experienced in handling…
Related
Other DOJ standards.
- DOJ41 citations
ST1166
DoJ Evaluation of Corporate Compliance Programs
- DOJ25 citations
ST1160
DoJ Evaluation of Corporate Compliance Programs
- DOJ24 citations
ST1154
DoJ Evaluation of Corporate Compliance Programs
- DOJ22 citations
ST0028
Evaluation of Corporate Compliance Programs
- DOJ22 citations
ST0535
Evaluation of Corporate Compliance Programs
Source & revisions
- First mapped
- Jun 8, 2022
- Last updated
- May 26, 2026 (15m ago)
- Source
- DoJ Evaluation of Corporate Compliance Programs