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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Arguably there is no more major a case in modern history than the Ponzi Scheme perpetrated against thousands of victims for more than three decades by the notorious Bernie Madoff.

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On April 3rd, 2016, information about 214,488 offshore companies established by Panamanian law firm Mossack Fonseca was leaked. Since the Panama Papers leak, a total of 81 jurisdictions worldwide have passed laws requiring beneficial ownership to be registered with a government authority. The U.S. Government has been openly critical of countries that act as money laundering safe havens and yet we were not taking any steps toward transparency. That changed on January 1, 2021 when both houses of Congress passed the National Defense Authorization Act for Fiscal Year 2021, which includes the Corporate Transparency Act (the Act). The Act requires a report be filed with the Financial Crimes Enforcement Network (FinCEN) that identifies each beneficial owner of an applicant forming a reporting company. 

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In the second part of this series, we discuss some important work my guests are involved with at the IBA’s Subcommittee on Non-trial Resolutions of Foreign Bribery Cases regarding the growing international use of settlements to resolve anti-corruption cases.

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In 2006, Germany-based Siemens was ranked 22nd on the Global Fortune 500 with revenues of $100 billion. It was a global leader and one of the world’s most admired companies. Until November 16, 2006 when the Munich Police Department raided Siemens corporate offices and several subsidiaries based on whistleblower allegations of bribery and misuse of funds. This Munich Police Department investigation triggered a global corruption investigation which revealed that Siemens had methodically violated U.S., German and other global anti-bribery laws for decades. When the settlement of the case was announced in 2008, law enforcement didn’t pull any punches.  Yet what is equally remarkable is that a company that used corruption strategically and methodically to achieve its business objectives for decades remade itself in the wake of the corruption scandal to emerge as a model of corporate reform and business ethics.  

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In this episode, we’re going to talk about the inter-relationship between major investigations and crisis communications. So much of crisis management planning and crisis communications is about thinking through various scenarios that could play out and then formulating a game plan for each.  

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Part 2 of this Fraud Eats Strategy series, Scott Moritz continues the conversation on the Anti-Money Laundering Act of 2020 (AMLA 2020) with Matt Biben, Partner of Gibson Dunn.

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