INDIA INVESTIGATIONS
Representative Matters · Corporate Compliance Investigations

Screening program for a dealer network

Tiered third-party screening for a consumer-appliances manufacturer
Client
a consumer-appliances manufacturer
Scope
its dealer network
Volume
nearly two hundred tiered screens

The matter

A large consumer-appliances manufacturer sells through dealers: hundreds of them, from private limited companies to family proprietorships, spread across the country. Each one carries the company's brand and its compliance exposure. The instruction was for a screening program covering the whole network.

“Report formats were set by entity type, because what you check on a proprietorship differs from what you check on a company.”

The work

The work, carried out during my tenure at a global investigations firm, ran at volume, with judgment applied to each report. Each dealer was screened to one of several tiers of depth, matched to its risk and scale. Report formats were templated by entity type, because what you check on a proprietorship (the proprietor) differs from what you check on a company (its shareholders, charges, and sister concerns). Nearly two hundred reports moved through the program, consistent enough to compare across the network, specific enough to act on individually.

Why it matters

In my observation, volume screening often fails in one of two ways: the depth falls to a database search, or the cost grows beyond what a business selling through dealers can carry. Tiering addresses both. Each dealer was screened to a depth that matched its risk, with a route to escalate when a quick screen raised a serious question. I set up third-party screening for compliance teams in India the same way now.

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