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.
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
On December 6, 2018, in New York City, the Securities & Exchange Commission (“SEC”) Chair Jay Clayton delivered his speech, where he outlined where the SEC stands on its rule-making
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
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.» Read More
Corporate governance is the collection of systems and processes that an organization has in place to prevent or dissuade potentially self-interested persons from engaging in activities detrimental to the welfare of shareholders and stakeholders and helps to promote better overall decision making.» Read More
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.» Read More
It’s a mistake to ignore the human element when fighting fraud within a corporation. There are behavioral and
Ultimately, a monitor should benefit the company, its employees, shareholders, and the public by effectively furthering the goal of preventing and detecting future misconduct.» Read More
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
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,
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
Baker Tilly Media Relations
Marks brings over 30 years of forensic accounting, investigations, governance, risk management and compliance experience to one of
The Department of Justice (DOJ) said in a release, “Executives at the highest levels of Petrobras — including members of its executive board and board of directors — facilitated the
Knowing who you conduct business within your supply chain is a very good if not leading business practice. Many organizations are being held responsible for the actions of their business
At some point it appears there was a human behavior theory that was possibly applied to fraud risk management and the 10-80-10 Rule to Ethics was born.
This theory is based on the assumption that 10 percent of the people are ethical all of the time, 80 percent could behave unethically depending on the situation or the pressure(s) being applied, and 10 percent have no or a severely broken moral compass and will pounce on opportunities to commit fraud.» Read More
While we can’t get into the mind of the white collar criminal, we can take a closer look at high-profile individuals who have perpetrated massive fraud at corporations and instances of fraud identified in practice, as well as some research, to help is identify a pattern of similar behavioral elements common to white-collar crooks and cultural elements common to their environments.» Read More