Aerospace & Defense Third Party Anti-Corruption Program – Brazil

January 6, 2023

In connection with ongoing negotiations with U.S. and Brazilian law enforcement and regulators, a Brazil-based aerospace and defense company needed assistance in the design, implementation and administration of their third-party anti-corruption program, the centerpiece of their newly revamped anti-bribery and corruption compliance program.  The team worked with compliance leadership to inventory the various categories of third party, isolate the intermediaries, harmonize the taxonomy used to describe the various intermediaries and develop a tailored risk scoring methodology that considered country, relationship, relationship size, nexus to government officials and state-owned entities and government agencies, watchlist findings and adverse disclosures.  The team also designed the entire onboarding work flow to include business sponsor forms, third party questionnaires, risk scoring, watchlist screening, investigative due diligence requisitions and fulfillment, interpretation of results, follow-up actions and decisioning.  The company’s third party anti-corruption program and other actions it took enabled them to enter into a favorable settlement with Brazilian and U.S. enforcement authorities.