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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.
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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.
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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.
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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.
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In part 2 of this series, we continue to discuss the tools that cybersecurity teams use to combat ransomware attacks.
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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.
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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.
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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.
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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.
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Las Vegas has come to symbolize the commercialization of gambling. Casino gaming has become an extension of the global hospitality and tourism business While the mob may not be the factor it once was, criminals are still attracted to casinos and as a result, illicit money still finds its way into casinos banks despite their devotion of considerable compliance and anti-money laundering resources designed at keeping it out. Financial crisis aside, casinos are the most profitable and desirable centerpieces of global hotel and casino gaming empires.
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The passage of Dodd-Frank represented a major overhaul of U.S. financial regulations. Among the Act’s most notable achievements were the creation of the U.S. Securities and Exchange Commission (“SEC”) Office of the Whistleblower and the SEC Whistleblower Program. In its short, 10-year history, the SEC Whistleblower Reward Program has been extraordinarily successful in enabling the SEC to root out securities fraud and protect investors. Since the inception of the SEC Whistleblower Program, the SEC has paid more than $900 million in awards to whistleblowers resulting in more than $3.5 billion in financial remedies. According to the SEC Whistleblower Program’s 2020 Annual Report, the SEC is tracking over 1,100 matters in which a whistleblower’s tip has caused a Matter Under Inquiry or investigation to open.
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Part 2 of this episode series continues the deep dive into Lava Jato or Operation Car Wash, the largest and most complex corruption investigation in the history of Brazil.
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In this episode, we’re going to discuss Lava Jato or Operation Car Wash - the largest and most complex corruption investigation in the history of Brazil which to date has spread to 11 countries, mostly in Latin America. When the Organisation of Economic Cooperation and Development – the OECD – published the Foreign Bribery Report in 2014 examining corruption enforcement across the world, Brazil was credited with zero corruption prosecutions.
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When we launched the “Fraud Eats Strategy” podcast, we promised to explore organized crime, boiler rooms, money launderers, warlords, kleptocrats and fallen CEOs, and the companies that have been damaged or destroyed through their criminality. Throughout the first 30 episodes, we hope that you have seen these efforts and enjoyed the content!
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When we first launched the “Fraud Eats Strategy” podcast series, we promised to explore organized crime, boiler rooms, money launderers, war lords, kleptocrats and fallen CEOs, and the companies that have been damaged or destroyed through their criminality. In the first 30 episodes, I like to think we’ve delivered on that promise.
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Beginning in November 2012 with the publication of A Resource Guide to the U.S. Foreign Corrupt Practices Act (commonly referred to as the FCPA Resource Guide), the U.S. Department of Justice and the Securities Exchange Commission have regularly been publishing useful and informative guidance on the elements of effective compliance programs and the Department and the Commission’s expectations. Following the publication of the FCPA Resource Guide, the DOJ Fraud Section published another important document in February 2017 entitled “Evaluation of Corporate Compliance Programs”. It has been updated twice since then in 2019 and again in 2020. The FCPA Resource Guide was also updated in 2020. These two documents are the primary desk references used by federal prosecutors to examine whether a company they are investigating has an “effective compliance program”. Because of that, it is incumbent upon board members and C-suite executives to be familiar with these documents, understand what is expected of them and to hold themselves and others accountable ensuring that the company has properly considered the risks of their unique business operations and has tailored a robust compliance program based upon a nuanced understanding of that risk.
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Rarely do we hear or read about the names of third-party bribe payers or the names of their companies. Global companies, particularly those who ship products internationally or rely on third-parties in other ways to bring their products and services to market, are heavily reliant on virtual armies of third-party intermediaries to operate internationally. They are a necessary evil who can act on an organization’s behalf, represent them in the marketplace and potentially trigger significant liability under the FCPA, sanctions or anti-money laundering laws.
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Part 2 of the special edition episode we continue the discussion of the most comprehensive and successful financial investigation and asset search in history; The Madoff Ponzi Scheme.
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