Most anti-corruption enforcement actions involve transfers through third-party intermediaries, but traditional approaches to third-party risk mitigation are not addressing the entire lifespan of risk. Most anti-corruption compliance programs devote an inordinate amount of resources to front-end due diligence and onboarding processes, which are imperfect in their ability to identify illegitimate third parties and to prevent legitimate third parties behaving badly once engaged. In a guest article, Parth Chanda, founder of Lextegrity, explains that to effectively mitigate third-party risk, an enterprise must look beyond due diligence and integrate continuous monitoring of third-party transactions on the back end. See “Transaction Monitoring Tips From the Experts at Google” (May 29, 2019).