KPMG Survey Finds Failure To Monitor Third Parties Heightens Bribery Risks

Although a very high proportion of bribes is being paid by third parties, many companies are not monitoring their intermediaries for anti-bribery and corruption (ABC) risk, according to the results of a new survey by KPMG International.


While many companies are performing due diligence when bringing third parties aboard, the majority of the survey respondents at U.S.-listed companies are not taking the next steps to monitor these intermediaries.

Despite 73 percent of companies indicating they have a formal risk-based third party onboarding process, only 45 percent have right to audit clauses in their third party contracts, with slightly more than half (23 percent of the total) of those exercising these rights.

Auditing third parties for ABC compliance ranked as the most challenging ABC issue faced by the respondents.

Effective monitoring starts with the identification of those that present the greatest risks, however less than three-quarters said their companies have a formal process to identify third parties from an ABC perspective.

The lack of ongoing monitoring is not restricted to companies’ third party policing efforts.

There is also room for improvement in regular monitoring in their own ABC compliance programs.

While 9 in 10 U.S.-listed respondents said their companies have a formal, written anti-bribery and corruption compliance program in place, only 68 percent said these programs include continuous monitoring and internal audit protocols.

“The good news is that as ABC compliance programs continue to mature, companies are being more proactive in their third party due diligence efforts,” said Phillip Ostwalt, partner and Global Investigations Network Leader at KPMG LLP. “However, companies are not consistently following through to evaluate their own ABC risks or those presented by their third parties. This failure is particularly significant given regulatory focus on ensuring that compliance programs are equipped to mitigate such risks.”

Oversight of third parties is the greatest challenge in managing ABC compliance programs because the role of these intermediaries in companies’ interactions with governments has grown and supply chains have become more complex amid business globalization.

According to the Foreign Bribery Report of the intergovernmental Organisation for Economic Co-operation and Development (OECD) released in 2014, more than three quarters of the 427 corruption cases analyzed involved third parties.


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