1. Review of the ABC/AML
risks and liabilities arising
from compliance failures in
business units at the far
end of the extended supply-
chain.
A.1 Review of the legal and compliance
policy differentials between local
requirements and international best
practice.
A.2 Analysis of the effect of local
compliance failures on the other
business units in the overall supply
chain.
A.3 Assess the ABC/AML risks arising from
local third party relationships.
(A)
Supply Chain Insight:-
Last-Link Compliance
2. Last-Link Compliance
Review of the ABC/AML
risks and liabilities arising
from compliance failures in
business units at the far
end of the extended supply-
chain.
(B)
Compliance In Practice:-
B.1 Evaluate the effectiveness of existing
(centrally directed) ABC policies,
procedures and controls operated by
the local business units and associates.
B.2 Integrate local ABC compliance
policies, procedures and controls with
international guidance and
requirements to develop a compliance
regime that meets end-to-end supply
chain requirements.
B.3 Review current third-party relationships
and the effectiveness of existing
compliance policies, procedures and
controls.
B.4 Develop appropriate third-party
compliance policies, procedures and
controls.
3. Last-Link Compliance
Review of the ABC/AML
risks and liabilities arising
from compliance failures in
business units at the far
end of the extended supply-
chain.
(C)
Training Workshop:-
C.1 International ABC/AML investigation
and enforcement: training on
compliance relevance to business units
at the far end of the supply chain.
C.2 ABC/AML threat analysis: training on
ABC/AML threat assessment,
investigation and enforcement
procedures, and handling compliance
breaches.
C.3 Post-COVID Changes: training on ABC
liabilities from online communications
and negotiation.
C.4 Compliance in Action: training on the
company’s compliance policy,
procedures and controls, corruption red
flags, and reporting procedures.
4. Last-Link Compliance
Review of the ABC/AML
risks and liabilities arising
from compliance failures in
business units at the far
end of the extended supply-
chain.
(D)
Review and Report:-
D.1 Specification of the methods,
procedures and process of the annual
internal compliance audit.
D.2 Assessment, analysis and report on the
annual internal compliance audit.
D.3 Review of the compliance regime; with
proposed amendments to the policies,
procedure and controls (if required).
D.4 Annual compliance report to senior
management.
5. Last-Link Compliance
Review of the ABC/AML
risks and liabilities arising
from compliance failures in
business units at the far
end of the extended supply-
chain.
(E)
Management Briefing:-
E.1 Boardroom Briefing: quarterly
communication to senior
management on ABC/AML
developments, investigation and
enforcement worldwide.
6. Last-Link Compliance
Review of the ABC/AML
risks and liabilities arising
from compliance failures in
business units at the far
end of the extended supply-
chain.
(F)
Compliance Consultations:-
F.1 Subjects for consultation limited to
matters covered or relevant to this fixed
price product..