Successor liability under the Foreign Corrupt Practices Act has been a risk for companies since the statute was first enacted. But until recently, the DOJ and SEC have been deliberately vague in terms of the guidance offered and their expectations about FCPA due diligence and the time imperatives surrounding post-merger integration as it relates to combining compliance programs. That all changed in October of 2023 when Deputy Attorney General Lisa O. Monaco announced the implementation of DOJ’s Safe Harbor Policy for voluntary self-disclosures made in connection with Mergers and Acquisitions.   Put succinctly, DAG Monaco said “we want to incentivize the acquiring company to timely disclose misconduct uncovered during the M&A process.” She further announced: “Going forward, acquiring companies that promptly and voluntarily disclose criminal misconduct within the Safe Harbor period, and that cooperate with the ensuing investigation, and engage in requisite, timely and appropriate remediation, restitution, and disgorgement – they will receive the presumption of a declination. Of particular note is that in order to qualify for the Safe Harbor, companies must disclose misconduct discovered at the acquired entity within six months from the date of closing. That applies whether the misconduct was discovered pre- or post-acquisition.

Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode, we delve into the psychology of white-collar criminals. White-criminal criminals are often treated differently than other categories of criminals which provokes a response unlike other crimes. White-collar criminals are not better than or more deserving of leniency than other categories of criminal, it’s just that they are wired differently and understanding that fact can better position us to help safeguard organizations from the types of crimes that white-collar criminals commit. Joining Scott on today's episode are two experts on the subject of white-collar crime psychology, Nicolas Bourtin and Eugene Soltes.  

For more information visit: https://fraudeatsstrategy.com/

Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode we have an ambition agenda. We are going to provide a high level overview of virtual currencies, blockchain technology and the vital role of crypto exchange, touch upon some spectacular failures in the crypto space, how the incidence of crypto crime is going down and the role that exchanges like Binance are playing in the mitigation of crypto crime.

Learn more about your ad choices. Visit megaphone.fm/adchoices

The FBI’s Behavioral Science Unit and Violent Crime’s Apprehension Program (ViCAP) help

coordinate cross border violent crime by assisting police departments with behavioral science profiling and by maintaining a massive law enforcement database on unsolved violent crimes largely serial murders. 

Joining me today is former FBI Assistant Director Frank Figliuzzi. In total, Frank served as a special agent for 25 years. Frank is the author of the new book: Long Haul: Hunting the Highway Serial Killers. It is an in-depth examination of this ongoing initiative by the

FBI together with police agencies throughout the U.S.

Learn more about your ad choices. Visit megaphone.fm/adchoices

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.

Learn more about your ad choices. Visit megaphone.fm/adchoices

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

Learn more about your ad choices. Visit megaphone.fm/adchoices

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

Learn more about your ad choices. Visit megaphone.fm/adchoices

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

Learn more about your ad choices. Visit megaphone.fm/adchoices

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

Learn more about your ad choices. Visit megaphone.fm/adchoices

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

Learn more about your ad choices. Visit megaphone.fm/adchoices