ST1156DOJDOJ

ST1156

Prosecutors should also assess whether the company knows the business rationale for needing the third party in the transaction, and the risks posed by third-party partners, including the third-party partners’ reputations and relationships, if any, with foreign officials. For example, a prosecutor…

Assess my company

Source text

As written.

Prosecutors should also assess whether the company knows the business rationale for needing the third party in the transaction, and the risks posed by third-party partners, including the third-party partners’ reputations and relationships, if any, with foreign officials. For example, a prosecutor should analyze whether the company has ensured that contract terms with third parties specifically describe the services to be performed, that the third party is actually performing the work, and that its compensation is commensurate with the work being provided in  that  industry  and  geographical  region.  Prosecutors  should  further  assess  whether  the company engaged in ongoing monitoring of the third-party relationships, be it through updated due diligence, training, audits, and/or annual compliance certifications by the third party.

Change history

When and why it changed.

Present in the original catalog

This standard has not changed since it was added.

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.

Source & revisions

First mapped
Jun 8, 2022
Last updated
Oct 28, 2026 (6d ago)
Source
DoJ Evaluation of Corporate Compliance Programs