Foreign Corrupt Practices Act Archives | Page 2 of 2

Combating Fraud Through Effective Internal Controls

“Fraud is not an accounting problem; it is a social phenomenon.” Joe Wells

Most companies will not readily admit that their organizations may be vulnerable to fraud.
According to the 2020 Report to the Nations published by the Association of Certified Fraud Examiners (“ACFE”), which contains an analysis of approximately 2,500 cases of occupational fraud that were investigated between January 2018 and September 2019, organizations lose 5% of their annual revenues to fraud. While this number is only a general estimate based on the opinion, it represents the collective observations of anti-fraud experts who together have investigated hundreds of thousands of fraud cases. Based on the ACFE’s study, the median loss caused by frauds was $125,000, with 21.0% of the cases resulting in losses of at least $1 million.

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January 9, 2019

Fraud tip Friday! The Grand Illusion

If you think Good Tone or Conduct from the Top means you have an ethical environment, guess again!

Some of your people are up to no good.

Train and

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December 28, 2018

Collusion, Conflicts of Interest, and Corruption!

Corruption can take many forms, but its root cause could and often does include a conflict of interest of some sort and possibly collusion.

OECD states, Conflict of interest

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December 24, 2018

Investigation Roundtable on January 23, 2019, in Center City Philadelphia – Register Today! CPE/CLE

Investigation Roundtable on January 23, 2019, in Center City Philadelphia

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December 20, 2018

Focus on the Bad Actors! DOJ Outlines Key Policy Revisions Re-Focusing on Individual Accountability

American Conference Institute’s 35th International Conference on the Foreign Corrupt Practices Act

“Fighting white-collar crime is a top priority for the Department, and we increased prosecutions in every

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November 30, 2018

Fraud and Related Party Transactions

Related party transactions could be a “red flag“, and must be evaluated with the proper skepticism! Perceived opportunities to commit management fraud include the ability of the fraudster to

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November 7, 2018

Compliance Thought Leaders You Should Be Following

Compiling a list of thought leaders in ethics and compliance is fun, but so challenging. There are simply too many thoughtful people in this field — which is itself enormous and wide-ranging — to call out everyone worth following. So below is a small slice of the thinkers in corporate ethics and compliance that I try to follow.
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October 22, 2018

DOJ Refines Monitorship Policies

Ultimately, a monitor should benefit the company, its employees, shareholders, and the public by effectively furthering the goal of preventing and detecting future misconduct.
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October 13, 2018

How Tight is Your Grip on Cash?

The treasurer of one of the largest oil companies in the United States recently learned the internal controls over the initiation of wire transfers were alarmingly loose. Every free-form

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October 12, 2018

FCPA – Cash, Bribes, and the “Four Eyes Principle”

At a minimum, as part of (emphasis added) your overall fraud risk management program, the following key processes/functions should be analyzed along with the embedded (key) internal controls,

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October 7, 2018

Registration is Now Open – Class Size is Limited! Doing Compliance Master Class Training with Tom Fox will be held in New York City on November 12-13 (Two Days), 2018.

I am pleased to announce the next offering of my Doing Compliance Master Class. I am partnering with Baker Tilly Virchow Krause, LLP, to put on a two-day class

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October 5, 2018

Compliance 101: Defining an Internal Control

July 2018

Last week I was speaking at an ethics and compliance event in Houston, where one of the other speakers stumped the crowd with a deceptively simple question: What

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July 16, 2018

Audit Committees, Internal Audit, and Fraud Risk

Audit committees (AC) are charged with overseeing financial reporting and audit processes in U.S. public companies. Scandals in the pre-Sarbanes-Oxley Act of 2002 (SOX) era (e.g.,

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February 1, 2018

Fraud Risk Assessment – A Recipe for Greater Success!

In addition to establishing an ethical environment, board members and management must also take the lead in implementing and maintaining a formal fraud risk management program. One key element of such a program is a fraud risk assessment.

Risk assessments are part of the discipline of risk management, where enhanced frameworks and techniques have emerged. Risk management comprises the identification, assessment, and prioritization of risks followed by the coordinated and efficient use of resources to monitor, minimize, and otherwise control the impact of the risks on the organization.

January 12, 2018