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.

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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.  

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

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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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In this episode, we're going to discuss the resumption of business travel and what that means to all of us.

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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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