Tag: Tone from the Top

Baker Tilly’s Global Forensic Investigations, Compliance and Integrity Practice expands its AML/BSA and Sanctions Services and Solutions!

Our experience conducting fraud investigations, domestically and globally, allows us to advise our clients on measures they can take to prevent fraud from occurring and detect issues before they expand. Our clients look to us to design anti-fraud programs and controls, perform anti-bribery and anti-corruption compliance assessments, and perform proactive fraud examinations to identify possible red flags or indicators of fraudulent activity. Because of our collective skills and the depth and breadth of our experiences, we are also able to design and enhance compliance programs and serve as integrity monitors. 

Correcting deficiencies, addressing gaps in controls, and remediation of specific issues is important at the end of every investigation to prevent the same or similar frauds from recurring.

We address these important client needs at the end of our investigations and can assist with implementing remedial actions.

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The Continued Evolution of Best Practices for Compliance Programs

In 2019 and 2020, the federal government released significant information which directly impacted compliance professionals. We cover all three releases in this eBook, the 2020 Evaluation of Corporate Compliance Programs – Guidance Document, the 2019 Framework for OFAC Compliance Commitments, and the 2019 Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations.

These three documents provided not only the government’s refreshed thinking on what constitutes a best practices compliance program. I have combined all three onto a best practices document.

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COVID-19 – Fraud On The Rise is No Surprise!

Last week, the Association of Certified Fraud Examiners (” ACFE”) published the results of a survey taken by more than 1,800 anti-fraud professionals in late April and early May 2020, while we were deep into the Covid-19 crisis.  The findings, for the most part, are not surprising, but does reveal some disappointing information.  While I have not seen a raw copy of the survey, I was surprised the ACFE didn’t ask if the company’s fraud risk assessment was reviewed and modified accordingly.

In addition, the survey highlights trends in the overall level of fraud. Survey respondents provided information about their current observations and expected changes regarding ten (10) specific types of fraud.

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Tone from the top: Leadership’s challenge during a crisis

Leaders must find ways to engage with their people to motivate them, and this becomes increasingly important during uncertain or trying times. If done correctly, talking can be incredibly powerful. It can help relieve anxiety and help people find the strength they didn’t know was in them. Studies have shown that talking shuts down the brain’s fear center.

As Dr. Judson A. Brewer stated in a recent New York Times article, “Anxiety is a strange beast. As a psychiatrist, I have learned that anxiety and its close cousin, panic, are both born from fear.”

Fear and anxiety can be debilitating. Without proper communication in a crisis, it’s easy for people to spin and spread stories of fear, creating social contagion. To balance this tendency, in a crisis, leaders need to take their “tone from the top” to the next level.

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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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Theranos: Too Good to Be True!

Overview – Fraud vs. Groundbreaking Science

Elizabeth Holmes (“Holmes”) founded Theranos in 2003 at 19 years old and dropped out of Stanford University to run the company. She marketed a

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Tone From the Top, the Next Level

As a result of COVID-19, the Board of Directors and Senior Management are challenged to monitor the cultural shifts of their organization and adjust their sensitivity and the frequency of communications as appropriate.

Leaders should always try to find ways to talk and engage with their people to motivate them, especially during these uncertain and trying times. If done correctly, talking can be incredibly powerful. It can help relieve anxiety (defined as “a feeling of worry, nervousness or unease, typically about an imminent event or something with an uncertain outcome”) and help people find the strength they didn’t know was in them. Studies have shown that talking shuts down the brain’s fear center.

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Board Awareness: Culture and Red Flags

Edgar Schein presents culture as a series of assumptions a person makes about the group in which they participate.
Below are some “red flags” that may indicate there is a problem with the culture of the organization.

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Structural Integrity! Chief Compliance Officer v. General Counsel – Should They Be Separate?

Lack of separation of the CHIEF COMPLIANCE OFFICER and the GENERAL COUNSEL has been cited as a cause of numerous corporate failures. In fact, separation is now the norm in Health Care organizations. In spite of numerous recommendations to separate the two functions, there is general agreement that the roles are closely related and frequent collaboration is required.

The issues relating to separation of the CHIEF COMPLIANCE OFFICER and the GENERAL COUNSEL are most often discussed in terms of the differences in their roles (below).

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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.

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