A Comprehensive Approach to Managing Fourth-Party Risks in Third-Party Risk Management Strategies

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SIG University Certified Third-Party Risk Management Professional (C3PRMP) program graduate Lokesh Bhatnagar provides descriptions to determine which 4th parties are material, and how to incorporate them into the post-contract phase in the lifecycle as well as effective risk monitoring and oversight.


In the increasingly interconnected global economy, organizations depend on third-party vendors and service providers to maintain efficient, competitive supply chains. Effective third-party risk management (TPRM) is vital to safeguard organizations against financial, operational, and reputational damage. However, many TPRM strategies often overlook the risks posed by fourth-party subcontractors, particularly those that are material to the organization. 

Understanding Materiality in Fourth-Party Risk

Before delving into the management of fourth-party risk, it is essential to grasp the concept of materiality. A material subcontractor is one whose failure or poor performance could significantly impact an organization's operations, reputation, or regulatory compliance. Factors contributing to a subcontractor's materiality include:

Sensitive data handling: Assess the risk associated with subcontractors managing confidential information, as they pose a higher risk of data breaches or misuse.

Impact on third-party service delivery: Evaluate how a subcontractor's performance could impair a third party's ability to deliver contracted products or services, possibly leading to operational disruptions.

Service recovery: Identify subcontractors crucial to recovery services provided by a third party in the event of disruptions or emergencies.

Customer interactions: Recognize subcontractors that interact directly with customers, as their failure to meet service or quality expectations can directly impact an organization's reputation.

Government involvement: Understand the risks associated with government-controlled subcontractors or intermediaries of government-controlled entities, as they may face unique regulatory or geopolitical challenges.

Consequences of Neglecting Fourth-Party Risk

Neglecting fourth-party risks, particularly those associated with material subcontractors can have significant repercussions for organizations. These consequences can manifest in various ways, including:

Financial losses: Organizations should be prepared for the potential direct and indirect consequences of fourth-party failures. These may encompass regulatory fines, penalties, and costs associated with remediation efforts.

Operational disruptions: It is essential to understand the risks posed by a fourth party's inability to deliver critical services or products. Such shortcomings can negatively impact an organization's capacity to serve its customers and achieve its objectives.

Legal and regulatory penalties: Organizations must recognize the potential legal and regulatory actions they may face if they fail to manage fourth-party risks adequately. These actions can include fines, sanctions, or other penalties.

Reputational harm: Organizations should be aware of the potential damage to their reputation if they are perceived to have neglected their duty to manage fourth-party risks effectively. This is especially true when dealing with material subcontractors, whose failures can have far-reaching consequences for the organization's standing in the market.

Best Practices for Effective Fourth-Party Risk Management

Comprehensive due diligence for subcontractors: Conduct thorough risk assessments of material subcontractors, considering their financial stability, compliance status, and operational capabilities.

Robust contractual agreements: Develop comprehensive contracts that clearly define the responsibilities and expectations of all parties involved, including fourth parties, and incorporate clauses for monitoring,

Continuous monitoring and oversight: Establish a comprehensive monitoring and oversight program to ensure that fourth parties adhere to contractual requirements, industry standards, and regulatory obligations, including periodic audits, performance reviews, and risk assessments to identify potential risks and vulnerabilities promptly.

Foster assertive communication and collaboration: Encourage open and transparent communication among all parties in the supply chain, including fourth parties, to facilitate the early identification and resolution of potential issues. Collaboration should extend to sharing best practices, risk mitigation strategies, and incident response plans.

Integrate fourth-party risk management into the overall risk management framework: Ensure that fourth-party risk management is seamlessly integrated into the organization's broader risk management strategy, including alignment with its risk appetite, governance structure, and risk reporting.

Develop contingency plans: Create robust contingency plans for critical fourth parties to ensure business continuity in the event of a fourth-party failure. These plans should include alternative suppliers, service providers, or recovery strategies that can be activated swiftly in case of disruptions or emergencies.

Continuous improvement and adaptation: Regularly review and update a fourth-party risk management program to accommodate changes in the organization's risk environment, regulatory landscape, and industry best practices. 


In the current dynamic global landscape, marked by intricate supply chains and an ever-growing reliance on third-party vendors, effective management of fourth-party risks, including material subcontractors, has become indispensable. Organizations that neglect to address these risks may face severe financial, operational, and reputational consequences. By incorporating the best practices outlined above, organizations can develop a comprehensive and proactive approach to fourth-party risk management, which will enhance the effectiveness of the organizations' TPRM strategies.

SIG University's Certified Third-Party Risk Management Professional (C3PRMP) program is a globally recognized certification that is the “gold standard” in terms of relevance, scope and content. The C3PRMP program was created by Linda Tuck Chapman, an advisor, educator, author and expert.


Lokesh Bhatnagar, Senior Service Delivery Leader, American Express
I am Lokesh Bhatnagar, a seasoned risk management professional with over 20 years of experience in the financial services industry, proudly serving as a Senior Service Delivery Leader at American Express for the past 17 years. Holding an MBA from the prestigious Indian Institute of Management, my extensive expertise encompasses internal control, process optimization, and governance in large-scale finance and global supply management operations. As a Certified Third-Party Risk Management Professional from SIG University, I have honed my skills in navigating the ever-evolving risk landscape. I am committed to sharing my insights with organizations to help them mitigate potential threats.
Throughout my career, I have demonstrated an unwavering dedication to driving business transformation, implementing cutting-edge solutions, and fostering operational excellence. One of my notable achievements includes being the co-inventor of the patent 'Data Extraction and Duplicate Detection,' which revolutionizes invoice processing by automating the identification of potential duplicate invoices using optical character recognition, similarity measures, and an identical model. This innovative solution streamlines the process and significantly reduces costs and errors.
My thought leadership in the field has been instrumental in developing innovative risk management strategies that have produced tangible results for businesses. I deeply understand the intricacies of third-party risk management and the importance of a robust first line of defense. In addition to my professional achievements, I am passionate about mentoring the next generation of leaders and contributing to developing a solid risk management community. I take pride in staying current with the latest industry trends, ensuring that my knowledge remains at the forefront of the field. My intellectual curiosity, extensive experience, and academic background have allowed me to build a solid foundation for continued success in the world of risk management.