Third Party Risk Assessment Policy Template for United States

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Key Requirements PROMPT example:

Third Party Risk Assessment Policy

"I need a Third Party Risk Assessment Policy for our fintech startup that focuses heavily on data security and regulatory compliance, particularly for vendors who will have access to our payment processing systems and customer data, to be implemented by March 2025."

Document background
The Third Party Risk Assessment Policy is essential for organizations operating in the United States that rely on external vendors and service providers. This document has become increasingly critical due to growing regulatory scrutiny and the need to manage complex vendor relationships effectively. It helps organizations comply with various federal and state regulations while protecting against operational, financial, reputational, and compliance risks. The policy typically includes risk assessment methodologies, due diligence requirements, monitoring procedures, and compliance controls.
Suggested Sections

1. Purpose and Scope: Defines the objectives and applicability of the policy

2. Definitions: Key terms and concepts used throughout the policy

3. Roles and Responsibilities: Defines who is responsible for various aspects of third-party risk management

4. Risk Assessment Process: Details the methodology for assessing third-party risks

5. Due Diligence Requirements: Outlines required vendor evaluation procedures

6. Risk Monitoring and Review: Procedures for ongoing monitoring and periodic review of third-party risks

7. Reporting Requirements: Requirements for internal reporting and escalation procedures

8. Policy Compliance: Enforcement and compliance requirements for the policy

Optional Sections

1. Industry-Specific Requirements: Additional requirements specific to regulated industries such as financial services, healthcare, or government contractors

2. International Considerations: Special requirements and considerations for international third-party relationships

3. Technology and Cybersecurity Requirements: Specific requirements for third parties with access to systems or sensitive data

4. Subcontractor Management: Requirements for managing fourth parties (subcontractors of third parties)

5. Emergency Management Procedures: Procedures for managing third-party relationships during emergencies or business disruptions

Suggested Schedules

1. Risk Assessment Template: Standardized template for conducting third-party risk assessments

2. Due Diligence Questionnaire: Standard questionnaire for vendor evaluation and assessment

3. Risk Classification Matrix: Framework for categorizing and scoring vendor risk levels

4. Compliance Checklist: Checklist of regulatory compliance requirements for third parties

5. Vendor Management Procedures: Detailed procedures for ongoing vendor relationship management

6. Regulatory Requirements Summary: Summary of applicable laws and regulations affecting third-party relationships

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Relevant legal definitions
Clauses
Industries

Sarbanes-Oxley Act (SOX): Federal law that establishes requirements for financial reporting and corporate governance, including internal controls that may affect third-party relationships.

Federal Information Security Management Act (FISMA): Legislation that defines a comprehensive framework to protect government information, operations and assets against natural or human threats.

Gramm-Leach-Bliley Act (GLBA): Requires financial institutions to explain their information-sharing practices and protect sensitive data, including data shared with third parties.

Health Insurance Portability and Accountability Act (HIPAA): Establishes standards for protecting sensitive patient health information, including requirements for business associates and third-party vendors.

Foreign Corrupt Practices Act (FCPA): Anti-corruption law that prohibits the payment of bribes to foreign officials and requires proper accounting practices, affecting third-party due diligence.

Bank Secrecy Act (BSA): Requires financial institutions to assist government agencies in detecting and preventing money laundering, including monitoring third-party activities.

USA PATRIOT Act: Expands BSA requirements and establishes anti-money laundering programs, including due diligence requirements for third-party relationships.

Payment Card Industry Data Security Standard (PCI DSS): Security standard for organizations that handle credit card information, including requirements for managing third-party service providers.

NIST Cybersecurity Framework: Voluntary framework of computer security guidance for organizations to better manage and reduce cybersecurity risks, including third-party risk management.

FFIEC Guidance: Provides guidance for financial institutions on third-party risk management, including vendor due diligence and ongoing monitoring.

California Consumer Privacy Act (CCPA): State law that enhances privacy rights and consumer protection for California residents, affecting how organizations and their third parties handle personal data.

General Data Protection Regulation (GDPR): EU regulation that may apply when handling EU resident data, including specific requirements for third-party data processors.

OCC/FRB/FDIC Guidance: Regulatory guidance from federal banking regulators on managing third-party relationships and associated risks.

Uniform Commercial Code (UCC): Standardized set of laws governing commercial transactions, including contracts with third parties.

NY DFS Cybersecurity Regulation: New York's regulation requiring financial institutions to implement comprehensive cybersecurity programs, including third-party risk management.

SEC Cybersecurity Requirements: Securities and Exchange Commission requirements for cybersecurity risk disclosure and management, including third-party risks.

Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

Find the exact document you need

Third Party Risk Assessment Policy

A U.S.-compliant policy document establishing procedures for assessing and managing risks associated with third-party business relationships.

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