Commentary on fraud, scams, scandals, and court cases.
 

Book Review: Bribery and Corruption: Navigating the Global Risks

Originally printed in The Value Examiner Bribery and Corruption: Navigating the Global Risks focuses primarily on the U.S. Foreign Corrupt Practices Act (FCPA), but also provides information on the U.K. Bribery Act and some other key international regulations. For the uninitiated, the early chapters of the book provide a good …

The Justice Department’s Slippery Slope: Enforcement Versus Regulation

Guest post by Michael Volkov, Esq. The Department of Justice is proud of its record on FCPA enforcement. They take credit whenever and wherever they can. They trumpet every settlement. They proudly proclaim that over half of last year’s criminal fines were collected for FCPA violations. They are entitled to …

Article at CFO.com: Investigating a Compliance Failure

How to determine the right mix of expertise for a fraud investigation. By Tracy Coenen, Contributor to CFO.com It’s every CFO’s worst nightmare: despite your best efforts, your company’s compliance program has failed. There are credible reports of fraud and corruption inside the company, and an initial analysis of the …

FCPA Guidance to be Released by Department of Justice

Guest Post by David Quinones, Executive Director, International Association for Asset Recovery While it was just a brief comment during a lengthy speech, United States Assistant Attorney General Lanny Breuer’s mention of impending guidance on the resurgent Foreign Corrupt Practices Act (FCPA) from the Justice Department Amendments made to the …

Michael Volkov on Internal Investigations: Best Practices

Guest Post by Michael Volkov In-House counsel and corporate compliance officers dodge bullets everyday as they stare down the barrels of aggressive prosecutors, regulators, civil litigants, whistleblowers, disgruntled employees and shareholders prodded by trial attorneys to file derivative suits at the drop of a hat. In the face of all …

Article at CFO.com: When Your Compliance Program Fails

The steps to take when an employee comes forward with a fraud tip, whether the allegations are false or not. By Tracy Coenen, Contributor to CFO.com You think your company has a robust compliance program to prevent financial-statement fraud, asset misappropriation, Foreign Corrupt Practices Act violations, and other financial frauds. …

When Your Compliance Program Fails

The steps to take when an employee compes forward with a fraud tip, whether the allegations are false or not. Tracy L. Coenen – CFO Magazine You think your company has a robust compliance program to prevent financial-statement fraud, asset misappropriation, Foreign Corrupt Practices Act violations, and other financial frauds. …

CFO Magazine: Creating a Culture of Compliance

I was recently quoted in CFO Magazine for an article on creating an ethical culture within companies. Below are a few excerpts, including my comments. In December, the federal government cited a “lax corporate control environment” at Alcatel, which extended right up to the CEO and CFO, as a primary …