As our last article discussed, the greatest threat to brand owners may well be their own partners. Inadequate anti-corruption compliance measures can subject a company to both civil and criminal liability for third-party corruption, as well as seriously tarnish its brand. According to Ernst & Young’s 12th Global Fraud Survey, 90 percent of Foreign Corrupt Practices Act (FCPA) cases involve third parties. For most multi-national companies, third parties are essential to their success, but simultaneously create risk in the anti-corruption area. Fortunately, there is a solution: implement an effective third-party due diligence program.