Category: Third Party

IIA Philadelphia and Baker Tilly’s Fraud & Ethics Symposium is Postponed! Stay tuned for the new date.

This one-day fraud symposium, sponsored by Baker Tilly’s Global Forensic, Compliance and Integrity Services, and Solutions Practice Group and hosted by the Institute of Internal Auditors, Philadelphia Chapter, will include topics such as:

•Culture
•Current trends in white-collar crime
•Tone is the middle
•Policy management
•Case study on a local fraud

Discover who will be speaking and register for the event!

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DOJ Updates FCPA Corporate Enforcement Policy

On November 20th, 2019, The Department of Justice (“DOJ”) announced updates to its Foreign Corrupt Practices Act (“FCPA”) Corporate Enforcement Policy. While the changes were relatively minor, the modifications underscored important principles surrounding the FCPA Corporate Enforcement Policy.  

This latest update follows extensive revisions made in March of this year and the announcement that the FCPA Policy will apply as non-binding guidance for all criminal cases; all reflect DOJ’s continued efforts to promote self-disclosures and provide clarity on DOJ’s approach for companies deciding whether to self-disclose. There is little doubt the DOJ has landed on a Corporate Enforcement Policy that took years to develop. The FCPA Corporate Enforcement Policy now applies to all corporate criminal prosecutions except Antirust Division criminal prosecutions that are guided by the Leniency Program. The DOJ is consistently applying the principles and appears to be very comfortable with the results.

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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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e-Book Compliance Program Game Plan

This e-book is intended as a guide for Chief Compliance Officers (CCOs) and those responsible for developing and implementing compliance policies and procedures for an organization. Compliance, when done properly

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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Fraud Tip Friday: Small Dollars, Big Problems

Last week, a Transit supervisor and five others were charged in connection with a scheme to steal over $2 million from the agency. The kicker: the payments were under the limit of $5,000 – roughly speaking, that’s over 400 payments!

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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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Third Party Red Flags

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

Author: Jonathan T. Marks, CPA, CFF, CFE


Partner, Firm Practice Leader - Global Fraud & Forensic Investigations, Compliance, & Integrity Services

Communication and work product may be privileged and confidential.

Attribution

The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at jtmarkscpa@gmail.com

Jonathan T. Marks, his firm, their affiliates, and all related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication.

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