Bringing Order to the Chaos: Navigating the Steps of an FCPA Investigation

Human trafficking is the fastest-growing transnational crime with more than 25 million people held in forced labor and sexual exploitation. As if these numbers aren't horrifying enough, 10 million of those trafficked people are children, and yet rarely are US organizations focused on human trafficking's impact on their operations, much less society as a whole. In fact, most of us consider human trafficking to be a problem occurring in developing countries and that there are more pressing issues that should demand our attention and compliance resources. That false narrative is part of what makes human trafficking so difficult to counter.

Host Scott Moritz was a guest speaker at the October NAVEX Next Virtual Conference joined by Gregory Coleman, a former FBI colleague, to discuss established investigation techniques and how some of these practices have changed in recent times. For more information visit: FraudEatsStrategy.com

In Part 2 of this series we continue the conversation of how to bring order to the chaos of the early days of an FCPA investigation. For more information visit FraudEatsStrategy.com

In part 1 of this Fraud Eats Strategy series, we discuss how to bring order to the chaos of the early days of an FCPA investigation and avoid mortgaging the company’s future in the process. For more information visit FraudEatsStrategy.com

In part 2 of this series, we continue to discuss the tools that cybersecurity teams use to combat ransomware attacks. For more information visit FraudEatsStrategy.com

Ransomware is a type of malware used by criminal organizations to gain unlawful access to computer networks and encrypt the data stored on those networks and render it unusable. The criminal organization then holds the data hostage until a ransom payment is made. If the ransom is not paid, the victim organization’s data will either remain encrypted and unusable or it could be released to the public.  For more information visit FraudEatsStrategy.com

Monitorships, transaction lookbacks and KYC remediations are the equivalents of a regulatory vote of no confidence. They can be incredibly disruptive, painful and can cost millions of dollars to implement. They are extreme measures that are taken when regulators have seen no improvement in succeeding regulatory exams or sometimes happen without warning when a criminal investigation reveals how an institution was at the center of a large scale money laundering or dollar clearing criminal enterprise and their anti-money laundering or sanctions compliance program and the controls underlying them failed in spectacular fashion. These epic anti-money laundering failures lead regulators to conclude that the existing program was so ineffective it is highly likely that suspicious activity, possibly a great deal of suspicious activity, has been going on undetected and unreported for a period of years.  For more information, visit FraudEatsStrategy.com

This episode features special guest Tom Fox, founder of the Compliance Podcast Network and Author of The Compliance Handbook: A Guide to Operationalizing Your Compliance Program.. Click the link for 20% off of your purchase. The discussion focuses on the guidance compliance officers can use as roadmaps when architecting their Ethics & Compliance programs and anti-bribery and corruption compliance programs specifically the document Evaluation of Ethics and Compliance Programs authored by then DOJ Compliance Consultant Hui Chen published in 2017.

Internal investigations often are conducted by company personnel who may not have investigative backgrounds. While that is a common scenario and perfectly appropriate, there are certain dos and don’ts that non-investigators should know about to avoid missteps that could undermine the investigation and limit its effectiveness.  For more information visit: FraudEatsStrategy.com

In this episode, we’re going to discuss insider threats. The term means different things to different people. Broadly, the term refers to any person or entity who has trusted insider access behind an organization’s firewall or inside their secure perimeter. “Insiders” include employees, officers, contractors, temporary workers, and certain categories of vendors and suppliers that either have unescorted access to an organization’s physical premises or who perform some type of important software or network function and have been granted administrator access to the organization’s network. All insiders pose a potential threat. It is a matter of degree and whether they have an inclination to abuse their position of trust.  For more information visit: https://fraudeatsstrategy.com/