# Third party due diligence
> Source: https://legalcode.md/skills/legalcode-third-party-due-diligence | [HTML version](https://legalcode.md/skills/legalcode-third-party-due-diligence)

Conduct anti-corruption due diligence on agents, distributors, joint venture partners, consultants, and other third-party intermediaries.

Conduct anti-corruption due diligence on agents, distributors, joint venture partners, consultants, and other third-party intermediaries. Covers risk tiering, red flag analysis, due diligence questionnaire (DDQ) design, sanctions and debarment screening, contractual anti-corruption provisions, and ongoing monitoring. Aligns with DOJ FCPA guidance and DOJ Guidelines for Evaluation of Corporate Compliance Programs, UK Bribery Act 2010 Section 7 "adequate procedures" and Ministry of Justice six principles, OECD Good Practice Guidance on Internal Controls Ethics and Compliance, and World Bank / multilateral development bank debarment framework. Use when onboarding a new agent, distributor, or JV partner in a high-risk jurisdiction; when reviewing the adequacy of an existing third-party compliance program; when designing or improving a third-party risk management (TPRM) workflow; when preparing for DOJ/SEC FCPA inquiry or UK SFO investigation; or when a specific third party has raised red flags. Triggers on: "third-party due diligence," "TPRM," "agent screening," "distributor compliance," "JV partner vetting," "FCPA third-party risk," "UK Bribery Act adequate procedures," "World Bank debarment," "PEP screening," "anti-corruption questionnaire," "beneficial ownership," "intermediary risk," "kickback risk," "sanctions screening agent," "government-official connection," "OECD third-party guidance."

This skill conducts structured anti-corruption due diligence on third-party intermediaries — agents, distributors, joint venture partners, consultants, representatives, resellers, and similar counterparties through whom a company transacts with or on behalf of foreign entities. **Covers:** - Third-party risk tiering (HIGH / MEDIUM / LOW) with documented rationale - Due diligence questionnaire (DDQ) design and analysis - Sanctions and debarment screening scope (OFAC, UN, EU, UK, World Bank/MDB cross-debarment) - Beneficial ownership and Politically Exposed Person (PEP) analysis - Red flag identification and escalation - Contractual anti-corruption provisions (representations, audit rights, termination) - Ongoing monitoring framework and re-screening triggers - Suitability determination: APPROVED / CONDITIONAL / NOT APPROVED **Does not:** - Replace a full ABAC program assessment (see `legalcode-anti-bribery-compliance`) - Constitute a legal opinion on FCPA, UK Bribery Act, or local anti-corruption exposure - Perform automated database screening (manual analysis only — screening platforms required for sanctions lists) - Apply exclusively to one jurisdiction — jurisdiction-agnostic with [JURISDICTION-SPECIFIC] markers; the user must verify local anti-corruption law requirements This skill is jurisdiction-agnostic. Third-party due diligence obligations arise under multiple overlapping regimes simultaneously; the organization's legal counsel must determine which regimes apply. **Primary regimes addressed:** | Regime | Jurisdiction | Third-Party Liability Hook ...

## Jurisdictions

Global



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