Insights

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” […]

One of my favorite sophomoric movies is Liar Liar.  The story line is this. Jim Carrey plays an attorney who makes his career lying to protect his clients.  When he lies to his son and then misses his birthday, his son’s birthday wish is that he can’t lie anymore. The 24 hours that follow his […]

There are many incredibly sophisticated ways to convert or “launder” illicit proceeds. Laundering money gives it the veneer of having been earned legitimately and enables the launderers to integrate their ill-gotten gains into the stream of commerce and make it indistinguishable from money earned through legitimate means. But some criminal organizations are less concerned about […]

Boston Consulting Group recently surveyed compliance personnel from 250 companies and the resulting study revealed an interesting development on how organizations are responding to financial and trade sanctions. The study showed that the dynamic sanctions landscape is moving geopolitical risk toward the top of the compliance agenda. As a result, organizations with sanctions risk must […]

The more data that you collect in an investigation, the more time-consuming the investigation becomes.   Computer hard drives, smart phones, tablets, cloud storage devices and email servers are frequently a source of evidence that can contain an overwhelming quantity of data and open the investigation and subsequent litigation to questions as to the proper handling […]

The U.S. Foreign Corrupt Practices Act permits the making of small bribes for “routine governmental administration” known as facilitating or “grease payments”. While including this exception into the law showed a lot of foresight and a nuanced understanding of the endemic corruption that exists across the world, as a practical matter, explaining in a policy […]

According to the website: Live Science, contrary to popular belief, ostriches don’t bury their heads in the sand, but they do lie down with their heads against the ground when they feel threatened.   Inexplicably, ostriches are not extinct given their approach to self defense.  Human executives cannot take this approach when faced with an organizational […]

Putting someone “under a microscope” is a way of describing when a person or organization needs to be closely examined to determine if there is hidden risk. Most often, an investigative firm to performs “investigative due diligence” sometimes referred to as a “background check”. Due diligence investigations can unearth important red flags of prior behavior, […]

Just like it is a prudent thing to look at your consumer credit report periodically for signs of identity theft, it is likewise prudent to periodically review your vendor master file sorted by aggregate spend. Who are your biggest vendors, what are you buying from them and are there any vendor names that are high on the aggregate spend list that are unexpected or unknown?