About Board and Fraud

Board and Fraud is a blog that aims to bring a practical approach to issues facing the board of directors and the audit committee specifically in the area of governance, risk management, compliance, and internal audit, with a strong focus on fraud, ethics, and internal controls.

Speaking and Training on Fraud, Compliance, Ethics, and More…

Welcome to my site. I have spoken and been the keynote speaker for many conferences, including the ABA, ACC, ACFE, IIA, and IMA to name a few. I have designed customized training for the board, senior leadership, legal, compliance, internal audit, and others for some of the world’s largest organizations.

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Fraud: Department of Justice (DOJ) Announces Procurement Collusion Strike Force

On November 5th, the Department of Justice announced the formation of the new Procurement Collusion Strike Force (PCSF) “focusing on deterring, detecting, investigating and prosecuting antitrust crimes, such as bid-rigging conspiracies and related fraudulent schemes, which undermine competition in government procurement, grant and program funding”.

The Strike Force is an inter-agency partnership comprised of prosecutors from the Antitrust Division, and prosecutors from thirteen (13) U.S. Attorneys’ Offices.  Aiding in the prosecutors’ efforts are investigation partners such as the Offices of Inspector Generals from the Department of Justice, Department of Defense, U.S. Postal Service, and General Services Administration Office. The Department of Justice’s announcement proclaimed that investigating and prosecuting those who “cheat, collude and seek to undermine the integrity of government procurement” will have more to concern themselves with when executing their crimes. Prosecutors and investigators alike expressed enthusiasm to be working as a part of this new team.

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Hidden Assets and Illegal Payments

Stuffed animals, loose bricks in basement walls, mattresses, caves, hollow tree trunks, holes in the ground, and safe deposit boxes have provided hiding spots.

Today, hiding assets may be a much more sophisticated endeavor, often involving investments, banks, and overseas financial transactions.

Investigators should consider using a defined process to pursue matters that involve a search for hidden assets and illegal payments.

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Board Member Composition: Participants, Passengers, and Prisoners?

As the organization’s ultimate decision-making body, the board of directors plays two critical roles: overseeing management on behalf of shareholders and other constituencies; and advising management, albeit with limited involvement in everyday company operations – nose in, hands off! The board should not attempt to run the operations of the organization; it should oversee how management runs the company.

I am amazed at how many members literally are not engaged, which reminded that one of the traits of an effective leader, or Pilot, is being a good team builder. But how can you build a good team if you don’t understand the players?  I’m not speaking about understanding their skills, I am speaking about understanding their level of engagement.  That amorphous concept most ignore.

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It’s a Hit! Third Party Due Diligence

Why do due diligence? The “knowing” standard of the US Foreign Corrupt Practices Act (FCPA) makes a company equally liable whether an improper payment is made to a “Foreign Official”¹ directly or through a third-party, such as an agent, distributor, reseller, or sub-contractor. To minimize their exposure to potential sanction under anti-bribery and corruption regulations such as the FCPA, companies need to apply appropriate due diligence, taking a proportionate and risk-based approach.

Potential due diligence efforts include direct requests for details on the background, expertise, and business experience, of relevant individuals. It is also important to know whether you are dealing with a Politically Exposed Person (PEP) or a State Owned Enterprise (SOE).

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Why GDPR Matters

Reposted from CFO.com

The GDPR could affect almost every U.S. consumer goods and services company, and plenty of other organizations, that do business in the

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