No Result
View All Result
SUBSCRIBE | NO FEES, NO PAYWALLS
MANAGE MY SUBSCRIPTION
NEWSLETTER
Corporate Compliance Insights
  • Home
  • About
    • About CCI
    • CCI Magazine
    • Writing for CCI
    • Career Connection
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Library
    • Download Whitepapers & Reports
    • Download eBooks
    • New: Living Your Best Compliance Life by Mary Shirley
    • New: Ethics and Compliance for Humans by Adam Balfour
    • 2021: Raise Your Game, Not Your Voice by Lentini-Walker & Tschida
    • CCI Press & Compliance Bookshelf
  • Podcasts
    • Great Women in Compliance
    • Unless: The Podcast (Hemma Lomax)
  • Research
  • Webinars
  • Events
  • Subscribe
Jump to a Section
  • At the Office
    • Ethics
    • HR Compliance
    • Leadership & Career
    • Well-Being at Work
  • Compliance & Risk
    • Compliance
    • FCPA
    • Fraud
    • Risk
  • Finserv & Audit
    • Financial Services
    • Internal Audit
  • Governance
    • ESG
    • Getting Governance Right
  • Infosec
    • Cybersecurity
    • Data Privacy
  • Opinion
    • Adam Balfour
    • Jim DeLoach
    • Mary Shirley
    • Yan Tougas
No Result
View All Result
Corporate Compliance Insights
Home Compliance

Design a Training Program that’s Right for Your Third Parties

by Valerie Charles
June 1, 2018
in Compliance, Featured
Design a Training Program that’s Right for Your Third Parties

When it comes to anti-corruption compliance risk, it’s no surprise to compliance officers that third parties represent the single greatest worry. Monitoring third parties requires a rigorous third-party due diligence program, which takes into consideration the characteristics of each external partner to implement a comprehensive and effective compliance training program. 

When it comes to anti-corruption compliance risk, it’s no surprise to compliance officers that third parties represent the single greatest worry. Statistics show that the overwhelming majority of Foreign Corrupt Practices Act (FCPA) cases and enforcement actions have involved third parties. Understandably, rigorous third-party due diligence programs become the focus of compliance departments.

However, though third-party due diligence is important, monitoring third parties after initiating a relationship requires just as many effort and resources. Your monitoring program could even impact your decision to onboard third parties in the first place, and comprehensive monitoring could allow you to take on more high-risk third parties. A monitoring program can include annual certifications, adverse media reports, new backgrounds checks or even full audits.

It could be said, in fact, that the ability to alter the behavior of anyone working for or on behalf of your company is the most effective form of mitigation. Let’s explore the mitigating role effective training can have on third-party risks in particular.

Considerations for setting up a third-party compliance training program

What type of third party is it?

To achieve a high level of accuracy when building out your compliance training program,

categorize your third parties. Not all types of third parties should undergo the same type of training, just as not all in-house employees are subject to the same training program.

Where are your third parties located?

Where your third party is determines what you should include in the training. Despite the fact that FCPA training and UK Bribery Act training should be delivered to most of your third parties, since these laws have global jurisdiction, local anti-bribery and corruption laws may differ from one place to another. Likewise, thresholds set for gifts and hospitality are not the same across geographies. Even cultural business practices diverge. Thus, identifying the location of your third parties should be one of the stepping stones to building out your third-party training program.

What are the needs of your third parties?

No generic, pre-packaged program can serve the purposes of your training. Tailor your compliance training to the needs of your third parties. The most classic example is to provide content in the local language, but considering the environment of your third party is also crucial. Ask yourself: Do they have access to computers to take the training? Should your training be customized to be accessed from a specific type of device? Would on-site training make more sense?

Can your third party identify with the training?

Training can be given in a variety of ways, but the more your third party can identify with it, the better. Including real-life scenarios, with which the third party can identify and which reflect his or her day-to-day tasks, will resonate more with the trainee. Again, consider the third party’s location and environment when coming up with personalized scenarios.

Implementing your new compliance training program

Create a compliance culture

Even though third parties are geographically removed from company headquarters,

creating a culture of compliance still applies to employees working on your behalf. Countless times, headlines have featured companies that were assumed to have—and may truly have had—a high level of transparency embroiled in corruption investigations or hit with large FCPA fines because some third party had bribed on the company’s behalf in Uzbekistan or Nigeria. Managers and employees who engage with third parties in high-risk countries should make it clear that that is not how you do business. If corrupt practices are widespread in your third party’s local environment, pressure to meet performance targets might push them in the unethical direction. Sensitize your third parties to adopt the values and business ethics of your company and not the local practices.

Centralize to customize

Especially for enterprises, it can be a challenge to join your due diligence program with your compliance training. Putting technology to good use could solve your problem. Centralizing all third party-related data in one place will provide you with the overview you need to customize your training to the different third-party groups. A clear visualization of high-, medium- and low-risk third-party groups will also allow you to make the right decisions on the frequency with which you should deliver compliance training. High-risk third parties will need to take training more often than low-risk ones.

Nudge your employees

Throughout compliance circles, nudging is another concept that has been closely associated with employee training. As much as training has been stressed as the means through which policies and procedures come to life, nudging, some argue, is more effective in steering towards the right behavior. Imagine the effect reminders, notifications of policies, code of conduct or other automated messaging could have on third parties submitting exception requests or filing expense reports. This effort would require implementing integrated and automated solutions to your compliance program. The effort, however, is definitely worth your while.

Keep calm and train on

In today’s complex, inter-connected business environment, third-party groups are indispensable. But they also carry significant compliance risk, so a solid plan for compliance training is a must. However, third-party groups differ by location and culture, so make sure the training is relevant to their daily lives. The best practices above will help you create a program that helps your organization avoid FCPA enforcement actions.


Previous Post

Making GDPR Compliance Easier with a GRC Tool

Next Post

Fintech & Banking: Weighing the Compliance Risks & Rewards

Valerie Charles

Valerie Charles

Valerie Charles, a Partner with StoneTurn, has more than a decade of experience in advising and defending companies under investigation, as well as those focused on implementing and improving their corporate compliance programs. She has deep experience serving both as outside counsel and as an in-house compliance leader. Valerie also has extensive expertise leveraging technology in both proactive and reactive compliance matters.

Related Posts

robot nurturing a good idea

Innovation vs. Compliance: In the Age of AI, Why Not Both?

by Asha Palmer
June 17, 2025

As governments scramble to regulate AI, forward-thinking companies are writing their own compliance playbooks

human robot working as team pie chart

Smart Machines, Smarter Humans: Why Compliance Still Needs a Human Touch

by Roman Eloshvili
June 17, 2025

From the 2008 financial crisis to everyday judgment calls, the case for keeping humans in the compliance loop

data privacy leader concept

Who’s Minding Your Data? The Case for Dedicated Privacy Leadership

by Daniel Barber
June 16, 2025

As state privacy laws multiply and AI introduces new vulnerabilities, the question isn't whether you need dedicated privacy expertise —...

abstract obscured data colorful

NIST’s Differential Privacy Guidelines: 6 Critical Areas for Secure Implementation

by Michelle Drolet
June 16, 2025

Standard de-identification methods remain vulnerable to sophisticated attacks, but differential privacy offers mathematical guarantees that scale with emerging threats

Next Post
Fintech & Banking: Weighing the Compliance Risks & Rewards

Fintech & Banking: Weighing the Compliance Risks & Rewards

No Result
View All Result

Privacy Policy | AI Policy

Founded in 2010, CCI is the web’s premier global independent news source for compliance, ethics, risk and information security. 

Got a news tip? Get in touch. Want a weekly round-up in your inbox? Sign up for free. No subscription fees, no paywalls. 

Follow Us

Browse Topics:

  • CCI Press
  • Compliance
  • Compliance Podcasts
  • Cybersecurity
  • Data Privacy
  • eBooks Published by CCI
  • Ethics
  • FCPA
  • Featured
  • Financial Services
  • Fraud
  • Governance
  • GRC Vendor News
  • HR Compliance
  • Internal Audit
  • Leadership and Career
  • On Demand Webinars
  • Opinion
  • Research
  • Resource Library
  • Risk
  • Uncategorized
  • Videos
  • Webinars
  • Well-Being
  • Whitepapers

© 2025 Corporate Compliance Insights

Welcome to CCI. This site uses cookies. Please click OK to accept. Privacy Policy
Cookie settingsACCEPT
Manage consent

Privacy Overview

This website uses cookies to improve your experience while you navigate through the website. Out of these, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. We also use third-party cookies that help us analyze and understand how you use this website. These cookies will be stored in your browser only with your consent. You also have the option to opt-out of these cookies. But opting out of some of these cookies may affect your browsing experience.
Necessary
Always Enabled
Necessary cookies are absolutely essential for the website to function properly. These cookies ensure basic functionalities and security features of the website, anonymously.
CookieDurationDescription
cookielawinfo-checbox-analytics11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checbox-functional11 monthsThe cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checbox-others11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-necessary11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-performance11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
viewed_cookie_policy11 monthsThe cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.
Functional
Functional cookies help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedbacks, and other third-party features.
Performance
Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.
Analytics
Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc.
Advertisement
Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. These cookies track visitors across websites and collect information to provide customized ads.
Others
Other uncategorized cookies are those that are being analyzed and have not been classified into a category as yet.
SAVE & ACCEPT
No Result
View All Result
  • Home
  • About
    • About CCI
    • CCI Magazine
    • Writing for CCI
    • Career Connection
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Library
    • Download Whitepapers & Reports
    • Download eBooks
    • New: Living Your Best Compliance Life by Mary Shirley
    • New: Ethics and Compliance for Humans by Adam Balfour
    • 2021: Raise Your Game, Not Your Voice by Lentini-Walker & Tschida
    • CCI Press & Compliance Bookshelf
  • Podcasts
    • Great Women in Compliance
    • Unless: The Podcast (Hemma Lomax)
  • Research
  • Webinars
  • Events
  • Subscribe

© 2025 Corporate Compliance Insights