Tag: White Collar Crime Investigations

Fraud

The Next Level of Investigations

Many investigations are currently being performed remotely, in concert with the general counsel, the chief compliance officer, the chief audit executive, and depending on the how the allegation was triaged, with outside counsel, a forensic accounting firm, and the board.  Even government prosecutors are interviewing witnesses remotely.

The primary goal of the interview is to elicit information in a non-coercive manner. My personal preference is always to conduct interviews face to face because I can control the subject and the environment, and evaluate the nonverbal behavior of the interviewee.  But, if performing a face-to-face interview is not possible, I suggest using video over the telephone.

This writing provides some suggestions for techniques to consider when conducting internal investigations remotely.

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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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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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Compliance Thought Leaders You Should Be Following by Matt Kelly

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.
How should we define a thought leader, exactly? I define it literally. First, someone who thinks about corporate compliance issues, and puts those thoughts into words. Some bloggers and tweeters, for example, do a superb job passing along what happened, but not why or how it happened. 

Second, thought leaders lead. They raise questions about what should or could happen in ethics and compliance, even if practical obstacles today make achieving those goals difficult right now. Thought leaders provide context around the events of today to suggest what might be possible tomorrow.

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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

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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