Creating a Culture of Compliance for Third-Party Risk Management

The beginning of the year is a great opportunity to reflect on lessons learned in the past year and set some new goals for your organization’s third-party risk management (TPRM) program. In addition to strategic or financial goals, you may also want to consider how to create a culture of compliance for both your organization and its third parties. This essentially means to create an environment where your organization and its third parties are consistently following all policies, rules, and regulations.

TPRM compliance extends beyond regulatory guidance, although it’s worth noting a few significant regulations, such as the recent Interagency Guidance on Third-Party Relationships, which became effective in June 2023, and various state privacy laws that are still being introduced and passed. When you create a culture of compliance for TPRM, your organization will have a unified and consistent approach to your third-party relationships.

How to Create a Culture of Compliance in Your Third-Party Risk Management Program

This idea of creating a culture of compliance can seem overwhelming if you don’t know where to begin. A simpler way to think about a “culture” is in the context of shared practices or habits that are easy for everyone to understand and follow. Those practices and habits will be different for every organization, but the following principles can apply to any TPRM program:

• Universal participation – Make sure everyone in your organization understands they have a role in TPRM compliance. Roles and responsibilities should be clearly outlined, along with well-developed policies and procedures.
• Intentional actions – Compliance can be easier to achieve when everyone understands the “why” behind each activity. Explain the value and benefits of TPRM, such as reducing costs and protecting your organization from business-disrupting events. You can also emphasize the consequences of noncompliance such regulatory scrutiny and reputational harm.
• Clear direction – Senior management and the board should be setting the “tone-from-the-top” by directing and overseeing your TPRM activities. This helps emphasize the expectation that compliance risk is just as important as other risk types like financial and operational. 
• Prioritize TPRM best practices – It’s important to set a culture of compliance by having actions that back it up. Practices like risk-based third-party due diligence, continuous monitoring, and contract management demonstrate the importance your organization places on compliance. These aren’t only regulatory requirements for many industries but are also considered best practices. 

Tips to Ensure Continued Third-Party Risk Management Compliance

TPRM compliance should be a continuous effort for everyone involved, but it’s not uncommon to lose focus when other business priorities demand attention. Here are four tips that will help ensure your culture of TPRM compliance continues: 

1. Stay alert and informed. Even if you aren’t in a regulated industry, it’s a best practice to stay informed of current regulatory expectations. Regulators have been known to modify their expectations based on new or emerging third-party risks, so it’s worth the effort to stay updated on current guidance and adjust your processes if needed. Compare your current TPRM processes against regulatory guidance and document any changes needed. 
2. Document and report. TPRM involves so many activities and data, which can be difficult to track without proper documentation and routine reporting. In general, you should be reporting certain TPRM data to senior management and the board, such as your critical vendor inventory and issue management.
3. Prepare for noncompliance. Dealing with noncompliance can be challenging, especially if you’re trying to figure out a solution in the moment. Think ahead and consider how you’ll identify and resolve noncompliance, whether it occurs internally within your organization or externally through your third-party vendors. It’s important to have a response plan in place in the event of noncompliance 
   
   
   Pro Tip: The contract is one of the best ways to set a tone of compliance with third-party vendors. Spell out specific regulations and expectations third-party vendors will need to follow and set penalties for noncompliance. 
4. Communicate often. Any updates or changes in regulations or TPRM program expectations should be documented and communicated both internally and externally to third-party vendors. Keep the doors open with employees and third-party vendors for any feedback or concerns. It’s important everyone understands the expectations and standards for your TPRM program. 

Creating a culture of compliance for your TPRM program will likely require some time and effort but the overall benefit can’t be overstated. When your organization is committed to pursuing TPRM compliance, you should eventually see the full value of your program.