Onboarding and periodic re-screening of vendors, distributors, agents and intermediaries.
Third parties acting on a company's behalf are the most persistent source of anti-bribery exposure, and the DOJ and SEC's own guidance treats risk-based diligence on those parties as a hallmark of an effective compliance programme. The practical problem is volume: a screening budget stretched across hundreds of counterparties usually degrades into a name search and a screenshot.
A fixed-fee report per counterparty makes documented diligence something you can run at onboarding and again at renewal, with a dated file that shows what was checked and by what method.
Run Level A across the counterparty population as the standing onboarding check. Escalate to Level B for intermediaries with government touchpoints, opaque ownership, or any flag the screen raises; use Level C where the counterparty sits in the physical supply chain and trade, ESG or labour exposure is in scope.
Distributor incorporated fourteen months before the tender it won; sole shareholder is the spouse of a serving procurement official in the same authority. No sanctions matches.
Screening tells you what the record shows on the date it was searched; it does not monitor. Counterparty risk changes, so re-run material relationships at renewal. Beneficial ownership registers are incomplete in several jurisdictions and some are not public at all — the report names each register consulted and each one that could not be reached.