Anti-bribery due diligence on every distributor, agent and vendor — cited red flags, conditions and a signed decision before the contract
Every distributor, agent and vendor checked for bribery risk before the contract is signed.
See one case, screen by screen ↓The business sponsor needs the distributor signed before the next tender round. Compliance needs to know who really owns it, whether anyone behind it sits on a procurement board, and why the term sheet carries a success fee. The questionnaire comes back signed as complete and accurate, and the analyst has to prove it is not.
That proof is slow, manual work: pulling registry extracts and offshore records to trace every owner to a person, clearing sanctions and PEP name hits one by one, reading local-language news for tenders and inquiries, and checking margins against the country benchmark. A High-tier review takes two to three weeks by hand — and the answer that should stop the deal, an undisclosed owner married to a tender board member, sits two levels down, in an offshore company record nobody had time to open.
Estimated split for a typical High-tier distributor review, by hand and with the solution. Waiting on the third party does not go away.
Specialist agents read, trace, screen and score every third party and write a cited dossier; the risk lead decides and signs.
Halvora Medical Trading Co. wants to import and distribute Corventa to public hospitals in four Vietnamese provinces, including tender bids. Its questionnaire comes back at 06:52. Here is what happens next, screen by screen, in the working solution.
Dana opens the solution to 12 open reviews — 5 High, 6 Medium, 1 Low — 5 items that need her, and 312 approved third parties under monitoring. The country map is coloured by country risk. Top of her list: Halvora Medical Trading Co., “Questionnaire in today · run due diligence”.
Vietnam — Elevated risk: “Public tenders dominate hospital sales · officials in procurement boards.”
TP-2051: a distributor in Ho Chi Minh City, sponsored by Minh Tran, General Manager Vietnam, worth USD 2.4 million a year. It was pre-screened High because it bids in public hospital tenders in an Elevated-risk country. The 62-question questionnaire, signed by director Pham Quoc Bao, opens next to the dossier with every answer highlighted.
The questionnaire reader turns 62 answers into 8 claims to check and marks 2 evasive ones: audit rights and the unnamed resellers. In parallel, the ownership tracer pulls the registry extract and an offshore company record, the screener runs 6 subjects across 4 sanctions lists and the PEP database, and the media reader searches 214 articles in Vietnamese and English. Each red flag lands in the left column as it is found.
“About 9 seconds here · 2–3 weeks by hand for a High-tier review.”
Six weighted factors on scorecard v4, each shown with its sources: government touchpoint 22 of 22, compensation 20 of 20, ownership transparency 20 of 20, country risk 15 of 20, adverse media 5 of 10, sanctions 0 of 8. Seven red flags — four high, two medium, one low — and five checks passed, including a wholesale licence valid to August 2028.
Agent recommendation: “Approve with conditions — only if the recusal or sale of the 30% stake is in writing before signing. Otherwise reject.”
The questionnaire lists “other investors 30%”. The registry names Lotus Ridge Holdings Ltd., a BVI company holding 30% since 2022. Its record names one beneficial owner, Le Thu Hanh — whose spouse, Tran Van Khoa, Deputy Director of the Provincial Department of Health, sits on the provincial drug procurement and tender board that approves the tenders Halvora would bid in.
On the ownership graph: “Click a box to open its source · red lines are the path to the red flag.”
Four answers contradict the evidence and three are incomplete. Answer 4.2 on government links is “No”. Audit rights are “Subject to discussion”. Answer 8.4 says no inquiry in five years, while a 2024 provincial tender review named the company. Payments are asked for to an account in Singapore. The agent drafts a correction request for answers 3.1, 4.2 and 8.4 in Vietnamese and English, sent through the supplier portal with the sponsor in copy.
“The questionnaire was signed by the director as complete and accurate.”
Le Thu Hanh matches a PEP record as a relative or close associate at 0.93 — name, year of birth 1979 and city — proposed as a true match. Two sanctions name hits are proposed as false positives: Pham Quoc Bao on OFAC SDN (born 1958 against 1974, different nationality) and Le Thu Hanh on the EU list (1962 against 1979). The 2024 tender review is proposed as relevant — the inspectors closed it with no action.
“Dispositions are suggestions until you confirm them.”
An 18% margin against the Vietnam hospital-channel benchmark of 8–12%: outside policy. A 3% success fee on the awarded tender value: not permitted. A USD 120,000 marketing fund at the distributor’s discretion: needs a control. A Singapore payment account: outside policy. Payment terms of 60 days: within range. At USD 2.4 million a year, the proposed terms cost USD 504,000 against USD 288,000 at the top of the benchmark.
“The USD 216,000 a year above the benchmark has no stated service behind it — excess margin is a classic way to fund improper payments.”
Eight proposed conditions cover all seven red flags: a written recusal or sale of the 30% stake, no success fee, the margin capped at 12%, payment only to Halvora’s account in Vietnam, audit rights, an anti-bribery clause with termination and annual certification, the three resellers named and reviewed, and quarterly monitoring. Untick one and the screen shows which red flag is left open — approving with it open goes to Omar Haddad, Chief Compliance Officer, as an exception.
Dana signs with her password, and the meaning is recorded with it: “I approve this third party with the conditions listed.” The conditions writer drafts the clause pack — conflict of interest, compensation, margin cap, payments, audit rights, anti-bribery, sub-distributors, monitoring — for Lena Ortiz in Legal. Minh Tran gets the conditions, Priya Raman releases the vendor in the ERP after contract signature, and the re-review is due Oct 7, 2027.
The same review, seen by the four people who carry it — what their week looked like, and what it looks like now.
Specialist agents read, trace, screen and score every third party and write a cited dossier; the risk lead decides and signs.
Reads the returned due diligence questionnaire — any format or language — and turns each answer into a claim to check against evidence, flagging unanswered or evasive answers.
Pulls the business registry extract and offshore company records and traces every owner of 10% or more to a person, up to four levels, reporting any owner the questionnaire did not name.
Screens the entity, owners, directors and beneficial owners against OFAC SDN, EU consolidated, UK and UN lists and the PEP and relatives database, and proposes a disposition for each hit with its match reasons.
Searches ten years of news, court and regulator sources in the local language and English for bribery, fraud, tender and sanctions terms, translates what matters and looks for later follow-ups.
Checks the licence register and compares the proposed term sheet — margin, fees, payment account, marketing funds — with the country benchmark and the anti-bribery policy.
Scores six factors — country, government touchpoint, compensation, ownership, adverse media and sanctions — to a score out of 100 and sets the tier with its reasons; any government link makes a third party High.
Writes the due diligence dossier with every red flag cited, proposes the conditions that mitigate each one, recommends a decision and drafts the clause pack for legal counsel.
Re-screens approved third parties every day and watches registries, licences, certifications and invoices against the approved terms and caps, opening an alert with the evidence.
Decides and e-signs. The agents propose; a named person decides.
Ask about any third party, red flag or rule — or tell it what to change. Answers cite the questionnaire, record or article they come from.
Why is Halvora Medical high risk?
Score 82 — High. Four things drive it: a 30% owner is the spouse of a provincial tender board member; the questionnaire said “No” to government links; a 3% tender success fee and an 18% margin against 8–12%; and payments to a Singapore account. The 2024 tender review was closed with no action, so it weighs less. Approval is recommended only with a written recusal or sale of the 30% stake.
Is the Singapore account allowed?
No. Policy 6.1 requires payment to an account in the third party’s name in the country of service. Halvora asked for a Singapore account “for currency reasons”. The proposed condition pays only to its Vietnamese account.
Which third parties are due for re-review this quarter?
Nine are due by year end, four of them High — the first is Saigon Event Partners on Oct 21, the last Lima Salud Consultores on Dec 15. Andes Medical Distribución, due Nov 14, is the priority because of yesterday’s news alert.
Add a rule: flag any success fee tied to a tender or approval
Done. Any success, contingency or award-linked fee in a term sheet now raises a High red flag and proposes the condition “remove the fee”, as policy 4.3 requires. It would have caught Halvora’s 3% tender fee and Al Noor’s registration fee. The rule is on in Settings and recorded in the audit trail.
13 screens from the working solution, on its sample data. Pick one to see it large.
Tiers, red-flag rules, re-review cycles and who signs are settings — and a threshold change shows how many reviews would move before you make it.
| Setting | Default | Choose from |
|---|---|---|
| High tier from score | 70 | 50 to 90, in steps of 5 — shows how many reviews would move |
| Medium tier from score | 40 | 20 to 65, in steps of 5 — shows how many reviews would move |
| Any government link makes a third party High | On | On · Off |
| Low tier clears on its own | On | On · Off |
| Re-review High every | 12 months | 12, 24 or 36 months, with annual certification |
| High-tier decision | Dana Okafor | Dana Okafor · Omar Haddad |
| Rejections and exceptions | Omar Haddad | Omar Haddad · Dana Okafor |
| Adverse media languages | All 24 languages | All 24 languages · English only |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution; by-hand figures are estimates · “estimated” = our estimate · Regulatory context: DOJ/SEC FCPA Resource Guide (2020), UK Bribery Act s.7. People and companies named on this page are characters in the working solution.
It is the risk-based check a company runs before it contracts a distributor, agent, CRO or vendor that acts for it or meets officials on its behalf: who owns it, whether it has links to government officials, whether it is sanctioned or in the news for bribery, and whether its fees make sense. The DOJ/SEC FCPA Resource Guide and the “adequate procedures” defence under section 7 of the UK Bribery Act both expect it. This solution does the evidence work and writes a cited dossier; a named person decides.
The risk scorer scores six factors from 0 to 4 — country risk, government touchpoint, compensation, ownership transparency, adverse media and sanctions — and weights them to a score out of 100 on your approved scorecard. In the working solution High starts at 70 and Medium at 40, any government link makes a third party High, and a true sanctions match blocks onboarding whatever the score.
For each hit the screener compares full name, date or year of birth, nationality and address, and proposes true match or false positive with the reasons and a match score. The analyst confirms or overturns each one; dispositions stay suggestions until a person confirms them.
Yes. The ownership tracer follows every owner of 10% or more through registry extracts and offshore company records, up to four levels, until it reaches a person, and draws the ownership graph with a citation on every link. Any owner the questionnaire did not name is reported as a red flag.
Yes. The adverse media reader searches news, court and regulator sources in the local language and English for the last ten years, discards articles about other people with the same name, keeps the original next to the translation, and looks for later follow-ups — such as a review closed with no action — before the finding is scored.
No. The agents recommend; a person decides every tier, disposition and approval. High-tier decisions are e-signed by the risk lead with the meaning recorded, legal counsel approves the clause pack, and approving with a red flag left open goes to the Chief Compliance Officer as an exception.
It is re-screened every day, and registry changes, licence expiry, annual certifications and invoices against the approved caps are watched. Each alert carries its evidence and is closed by a person. Re-reviews come due on the tier’s schedule — every 12 months for High and 24 for Medium in the working solution.
The Agentic Solution Engine builds and deploys it from your requirements — your anti-bribery policy, questionnaire, country risk list, compensation benchmarks and a sample of past reviews — and it goes live once every quality gate has passed. We will walk you through it on your own third parties first.
Every speaker program scored against the OIG's eight red flags, before and after it runs.
1-min filmPayment RecipientsEvery payment to a clinician or teaching hospital matched to the right registry record, with the evidence behind each match.
1-min filmInvestigation BuilderEvery investigation starts with its evidence gathered, ordered and cited, and closes in a median of 18 days.
1-min filmWe’ll run Third-Party Due Diligence on a sample of your own distributors, agents and vendors.