Member companies often struggle with determining how much due diligence is required on certain types of commercial intermediaries. Service providers such as overseas law firms, real estate agents and other “non-traditional” intermediaries that have limited interaction with government officials may not pose the same compliance risk to companies as traditional commercial intermediaries that market and promote products. To help member companies conduct the appropriate type of due diligence on various commercial intermediaries, TRACE has created tiered due diligence guidelines based on extensive benchmarking and is now offering TRACEcheck, a new service designed to provide member companies with all necessary information on lower-risk intermediaries.
Information Collected
TRACEcheck is an almost entirely automated, streamlined due diligence service. The following information is compiled during the TRACEcheck process and included in the TRACEcheck report:
Business information
Ownership information
Identity of directors and key employees
Current government employment of owners, directors and key employees
Government employment of owners, directors and key employees within the previous two years
Standard compliance questionnaire
Self-certification of financial stability
One business reference
A media search in a comprehensive international database
Denied party screening search results
FCPA compliance certification
Examples of Intermediaries Eligible for a TRACEcheck Review
Service providers such as law firms, real estate agents, accounting firms and public relations firms
True resellers with low sales volumes or low value sales
The intermediaries of a merger partner
Member companies can also use this service to pre-vet a number of “traditional” intermediaries in
a given territory in order to determine which are appropriate for selection and a full due diligence review.
Process
Member companies buy electronic codes for $500 each and provide these codes to the intermediaries they wish to vet through TRACEcheck. The intermediary then goes to the TRACEcheck website, enters the code and inputs their information into the electronic questionnaire. Once the intermediary completes and submits the questionnaire, TRACE will receive the report and will conduct a media search, a denied party search and a brief review to ensure that all of the required fields contain legitimate information. Member companies will be notified when a report is complete, and they can log on to the TRACEcheck website to view or print a PDF version of the report. Any red flags found during the process will be highlighted in the report.
Intermediaries processed through TRACEcheck will not receive TRACE membership. This service is intended only as an information gathering tool that will help companies ensure that there is no adverse information regarding lower-risk intermediaries. It is the requesting company’s responsibility to follow up on any red flags.