Steele Introduces New StepOne Risk Inventory™ for FCPA Anti-Corruption Compliance

The Steele Foundation™, a global provider of business advisory, investigative and risk management services, today introduced a new StepOne Risk Inventory™ methodology that systematically identifies and assesses corruption risk associated with global third-party intermediaries, setting an industry standard for compliance with the Foreign Corrupt Practices Act.

“We found over time that many of our clients – ranging from the most complex Fortune 100 corporations to comparatively streamlined mid-sized companies – were overwhelmed by the process of identifying exactly who they were doing business with overseas and what levels of due diligence were necessary in order to adequately reduce exposure to corruption risk,” said Kenneth Kurtz, CEO at STEELE, which conducts compliance-driven investigations throughout established and emerging markets worldwide.

Evolved in consultation with multinational clients and based on Department of Justice and Securities and Exchange Commission cumulative guideposts, STEELE’s new StepOne Risk Inventory enables companies to define and analyze their third-party relationships and associated corruption vulnerabilities using a risk-based approach. This breakthrough methodology responds to the challenge companies face in defining exposures posed by disparate global third-party business relationships, establishing the framework for a credible, systematic vetting program that meets regulatory expectations.

The StepOne Risk Inventory is an assessment process that ultimately delivers companies a risk matrix to apply to all categories of third-party intermediaries, including joint venture partners, resellers, vendors, consultants, sales and marketing representatives, import-export and other agents and facilitators overseas. Using a proprietary calculator that weights risks based on a range of objective business factors, the process systematically defines relative levels of exposure and provides a roadmap for assigning appropriate levels of due diligence investigation applicable across industry sectors, departments and geographic regions.

Exponential growth in the number of federal investigations, multi-million dollar fines, jail time for executives, negative media coverage and related shareholder lawsuits have driven increased interest among corporate legal and compliance officers in renewed efforts to meet FCPA standards. “Putting in place a consistent, intentional third-party due diligence program is essential to demonstrating credible efforts to that end,” said Kurtz. “Companies want to do the right thing and execute on their anti-corruption policies out in the field, where the commitment counts. StepOne provides our clients the clear, cost-effective process they need to implement a meaningful third-party due diligence program for FCPA compliance.”

About Steele

Steele is a longtime global business advisory and risk management company providing investigative, security and consulting services for multinational Fortune 500 companies, as well as small and mid-sized businesses, governmental and nonprofit organizations. With regional offices in 16 strategic locations around the world, and engagements in over 90 countries, Steele’s solutions respond to the complexity of doing business in today’s fluid, outsourced marketplace. Specialized local expertise includes intellectual property and brand protection, compliance auditing, forensic accounting, due diligence and background investigations, incident management, emergency response and executive protection.

With 20 years of experience in the field and an international roster of top experts from a range of relevant disciplines, Steele sets the industry standard for innovative, professional and highly personalized crisis and risk management throughout the enterprise. For more information, visit www.steelefoundation.com.