Due Diligence and Ongoing Monitoring

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  • 1.  Exempt Third Parties

    Posted 10-04-2024 06:03 PM

    Are there certain vendors anyone excludes from inputting into the third-party software program?

    For example: 

    • the company is buying a car from a dealer
    • Purchase of office furniture

    These are just a few examples I think of that would be 'one-time use' so would it be worthwhile to complete an inherent risk assessment for a vendor that has almost 0 risk and would probably not be used again for a long time.



  • 2.  RE: Exempt Third Parties

    Posted 10-07-2024 08:38 AM

    For my organization, we don't exempt them- we tier them as low risk and only perform minimal due diligence such as anti bribery and corruption checks.

     

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  • 3.  RE: Exempt Third Parties

    Posted 10-07-2024 11:48 AM

    We use this clarifier in our program document: 

     Third Party Relationships that are not in scope for the TPRM program (but may still be part of the
    vendor inventory to align with the appropriate internal relationship owners) are: government
    agencies, public utilities, office supplies, annual dues or fees for professional association
    memberships and subscriptions, charities, entities from which travel, meals and entertainment are
    purchased, the US Postal Service, payee relationships (for legal settlements or payments to board
    members), and Corporate Sponsorships and/or donations.



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    Jenn Wilkinson
    Vice President
    Third Party Risk Management
    Cenlar FSB
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