Category: Uncategorized

In most investigative scenarios, it is important to question everything, not take things at face value and to be skeptical including when interviewing witnesses. In hotline investigations however, it is sometimes necessary to suspend cynicism in order to avoid potentially biasing the investigation.  An active, well-promoted hotline produces a steady volume of alerts for compliance, […]

Successor liability is when an acquiring company “inherits” the past illegal acts of a company it has acquired IF it fails to identify and report them as it goes through the processes of merger and acquisition due diligence and merger integration. Sellers often put their best foot forward when courting suitors. The amount of information […]

Crafting the subject line of an email can be a work of artistry. Done well, it is not unlike an attention-grabbing tabloid headline that compels the reader to act. Today, I received one such email with the subject line: Fixing the Problem and I was immediately hooked. What struck me is the term “fixing the […]

All organizations lose revenues to fraud and corruption, but most don’t realize it is happening. The Association of Certified Fraud Examiners (ACFE) – a global organization of fraud investigators with over 90,000 members – is best known for it’s widely cited statistic that 5% of revenue is lost each year to fraud. With Global World […]

There is a special place in Hell for criminals who target the lonely and the heartbroken – or so we like to think. But that timing doesn’t work for me. Rather than waiting for the hereafter for criminals to receive their well-earned punishment, let’s talk about how to move up the timeline for them to […]

Organizations are expected to have investigative capabilities, yet the majority do not. In fact, the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) consider confidential reporting and internal investigation to be among the most critical hallmarks of an effective compliance program. A very important initial step toward meeting the government’s compliance […]

Background investigations of counterparties in business transactions have been part of the business landscape for decades.  Commercial lenders, investors, business partners, underwriters, accounting firms, banks, and other legal entities routinely conduct background investigations before moving forward with a transaction, consummating a new business relationship or taking on a new customer.  The investigating party is hoping […]

Roughly two years into my FBI career (circa 1988), my eldest sister Meryl bought me a book called Gumshoe: Reflections in a Private Eye.  It is an autobiography written by Josiah  “Tink” Thompson, a former philosophy professor from Haverford College and Yale graduate who left academia to become a private detective.  The memoir is about […]

The World Economic Forum recently released its Global Risks Report 2023. The report highlights and examines perceptions of risks that will impact us the most both over the near term as well as over the next 10 years. Let’s focus on some that can have a direct affect on organizations, their assets and most importantly, […]

On January 1st of 2021, Congress enacted the Anti-Money Laundering Act of 2020. This is the most comprehensive set of reforms to U.S. anti-money laundering (“AML”) laws since the passage of the USA PATRIOT Act in 2001. AMLA 2020 created a whistleblower program that emulates the SEC Whistleblower Program in many ways. While this was […]

Being an investigator or compliance officer often requires you to learn about new products, technologies and fraud exploits arising from them.  Virtual currencies and blockchain technology may not be new but they are becoming more mainstream and ubiquitous.  At the same time, there is heightened regulatory and law enforcement attention being paid to cryptocurrency exchanges, […]

Many holidays and celebrations involve the exchange of gifts. Gift-giving traditions are an equally important part of the business landscape across the world. Unfortunately, the solicitation and payment of bribes is also a tradition that goes back for centuries. That is what makes gift-giving traditions and practices fraught with risk. Gifts are “something of value” […]