This Checklist outlines the key steps to take and the principal issues to consider when developing and implementing a risk-based due diligence program for investigating third parties in commercial transactions. It addresses building support for the program, coordinating internal resources, preliminary risk assessments, third-party risk profiles, risk-based due diligence levels, managing due diligence findings, resolving and mitigating risks or red flags, approving and monitoring third parties, program modification, and program documentation.