Due Diligence Checklist: A Step-by-Step Guide to Managing Third-Party Bribery and Corruption Risk in 2025

The rise of global enforcement actions, ESG mandates, and AI regulations means organizations must rethink how they vet partners, suppliers, and acquisitions. Whether you're entering a new market or onboarding a vendor, this 2025 due diligence checklist outlines exactly what to consider, so your business can stay compliant, ethical, and opportunity-ready.

Keep reading for a summary or click "download" to see the full checklist—no email required! 

• Why due diligence is non-negotiable in 2025
• A step-by-step checklist
• Choose the right tools

Why due diligence is non-negotiable in 2025

Compliance requirements have evolved dramatically. Businesses now face:

1. Stricter anti-bribery laws like the U.S. FCPA, UK Bribery Act, and new regional statutes.
2. Mandatory ESG due diligence in the EU, Germany, Australia, and beyond.
3. New AI regulations that require responsible sourcing and oversight of third-party tech and data vendors.
4. Increased cross-border enforcement, meaning violations in one jurisdiction can lead to global consequences.

As CEOs increasingly recognize due diligence as a growth enabler—not just a safeguard—compliance professionals are being asked to assess risk and opportunity simultaneously.

A step-by-step due diligence checklist for 2025

1. Conduct a risk-based assessment 

Start by mapping risk levels for each third-party relationship:

• Low risk: Local, transparent businesses → perform simplified due diligence.
• Medium risk: Emerging markets, complex supply chains → enhanced due diligence.
• High risk: PEPs involved, unknown ownership, tech/data risks → consider third-party investigations.

2. Screen for global compliance risks

Check for exposure to foreign laws. Anti-bribery legislation increasingly applies extraterritorially. Watch for red flags in:

• The U.S. FCPA, including the 2023 Foreign Extortion Prevention Act
• EU regulations like the Corporate Sustainability Due Diligence Directive
• Sector-specific frameworks in regions like the Middle East, Africa, and Asia

3. Evaluate ESG and human rights compliance

In 2025, ESG screening is mandatory in many jurisdictions and expected by stakeholders everywhere. Assess:

• Environmental performance (e.g. emissions, supply chain pollution)
• Human rights risks (e.g. forced labor, child labor, modern slavery)
• Governance issues (e.g. lack of transparency, corruption)

4. Include AI and tech due diligence

With the EU AI Act, DORA, and other global frameworks taking effect, companies must now evaluate:

• Whether third-party tech or AI vendors comply with regulatory frameworks
• Ethical sourcing of AI training data
• Transparency of AI-generated outputs

5. Validate business identity and ownership

Collect and verify:

• Company registration, shareholders, UBOs (Ultimate Beneficial Owners)
• Board members and management bios
• Past bankruptcies or legal actions
• Evidence of third-party relationships, especially with PEPs

6. Monitor continuously

Due diligence is not a one-time task. Regulators expect ongoing monitoring, including:

• Automated alerts for new sanctions, legal cases, or negative news
• Periodic rescreening of PEP lists and ESG performance
• Workflow and audit-trail tools to demonstrate compliance

Choosing the right tools

When selecting a solution, prioritize:

• Comprehensive coverage (ESG, AI, legal, sanctions, ownership)
• Efficiency at scale (batch processing, risk scoring, alerts)
• Auditability and security
• Integration with existing compliance workflows

Download the checklist

Your due diligence checklist is more than a compliance tool. In 2025, it’s a competitive advantage. Companies that demonstrate strong oversight, ESG impact, and responsible AI usage are more likely to win trust—and business.

Download the checklist and reach out if LexisNexis can help you future-proof your business. 

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