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Join us to hear about crime families, penny stock boiler rooms, international money launderers, narco-traffickers, oligarchs, dictators, warlords, and kleptocrats. The Fraud Eats Strategy series is the distillation of Scott Moritz's experience forged over thirty-plus years, whether it's an accounting scandal, arrests, search warrants, loss of market cap, or all of those things at once – one thing is sure. Failure to consider fraud and corruption risk can upend your strategy and lead to disaster.
 
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Today's 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. Our discussion focuses on the guidance compliance officers can use as roadmaps when architecting their Ethics & Compliance…
 
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. For more information v…
 
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 categori…
 
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…
 
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 extraordi…
 
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 …
 
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! For mo…
 
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. For more informat…
 
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…
 
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 internatio…
 
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 th…
 
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 …
 
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. For more information visit: https://fraudeatsstrategy.com…
 
In this episode, we’re going to discuss the Anti-Money Laundering Act of 2020 (AMLA 2020). This is the most comprehensive set of reforms to U.S. anti-money laundering (“AML”) laws since the passage of the USA PATRIOT Act in 2001. While there is a lot to the Act, there are some important changes and enhancements that should have an immediate and lon…
 
Cybersecurity is at the top of most organizations’ list of critical risks and is often cited by C-suite executives and Board Members as their gravest concern. Threats that are this complex and amorphous require strong partnerships including the inside of the organization. At first glance, cybersecurity and internal audit would seem to have very lit…
 
In this episode, we discuss trade-based money laundering. According to the intergovernmental money laundering and terrorist financing watchdog the Financial Action Task Force (FATF), there are three primary methods that transnational criminal and terrorist organizations utilize to launder the proceeds of illicit activity and use illicit proceeds to…
 
Conducting investigations in certain parts of the world can be challenging because of the business practices, language barriers and cultural differences. In some of those countries, they are discouraged or even unlawful. When you overlay travel restrictions during a global health crisis, challenging doesn’t begin to describe it. In this episode, we…
 
Most financial services companies above a certain size have one or more Financial Investigations Units (FIUs) and Special Investigations Units (SIUs) to investigate various threats against the institution and/or its customers. The missions vary from those that narrowly focus on risks such as card fraud and elder financial fraud, to those focused br…
 
In this episode we look inside the United Nations and its various agencies. We assess the harsh reality of endemic corruption in how governments intersect with UN agencies. Given its unique mission, the nature of how it is funded and disbursed funds largely for things such as large-scale infrastructure building, healthcare, education and peace-keep…
 
In this episode we examine pump and dump schemes in which thinly traded penny stocks are held by unscrupulous broker-dealers through nominees who push the stock on unsophisticated investors, drive up the share prices and then sell their shares at inflated prices causing the stock value to drop significantly. The term pump and dump is not widely kno…
 
In this episode, we’re going to explore the little-known area of “shadow investigations” in which accounting firms oversee internal investigations being performed by outside counsel and their forensic investigations counterparts in an effort to ensure the investigation is scoped appropriately such that it will provide sufficient information for the…
 
In this episode of Fraud Eats Strategy , we discuss why we need compliance officers now more than ever. The workforce that emerges from the combination of stay at home orders and the financial crisis will be very different than ever before. Each of us is dealing with unprecedented levels of stress, anxiety, and uncertainty. These external stressors…
 
In today's episode, we examine the often opaque, secretive world of fine art and how billions of dollars, a lot of which is from unknown origins, leads to the sales of fine art. Joining us to talk about this subject is Kobre & Kim partner Rob Rathmell. Rob specializes in providing offensive, counter-offensive, and defensive strategies for high-net-…
 
In this episode we discuss the Office of Foreign Assets Control (OFAC) sanctions and other areas of sanctions compliance and the inherent challenges of operating a company in compliance with U.S. and international sanctions when the lists of sanctioned parties are a moving target. Joining us are two experts on the subject of U.S. Trade and Economic…
 
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 di…
 
In this episode, we discuss the rapidly expanding use of artificial intelligence, machine learning and robotic process automation to undertake trade surveillance and mitigate fraud. Joining me today are two experts on the subject of Artificial intelligence from both the technical and legal and compliance perspectives. For more information visit: ht…
 
In this episode, we talk about the uncomfortable and sometimes terrifying situation when a compliance officer must critique a member of leadership team and living to tell about it. In recent years, the expression “tone at the top” has been displaced by “conduct at the top” ushering in a new era of leadership accountability and transparency by the D…
 
In this episode we going explore “bullet-proofing” your FCPA acquisition due diligence, merger integration and the government’s recent revisions to the FCPA Resource Guide and Evaluation of Corporate Compliance Programs guidance. Gone are the days when the potential bribery and corruption risk of an acquisition can afford to be something assessed a…
 
In this episode, we talk about why this may be exactly the right time to perform a meaningful fraud risk assessment. Fraud risks are like potential explosions. The vulnerability of fraud can lay dormant for years until and unless someone in a position to exploit the control weakness, formulates a rationalization and is off and running. Joining us t…
 
In this episode, we talk about the importance of seeing your compliance program through the government’s eyes. The DOJ Fraud Section recently released its latest update to their guidance on evaluation of corporate compliance programs. While it does not represent a major rewrite, it did provide further clarity on the government’s expectations on pos…
 
In this episode, we talk about one of the more challenging aspects of regulatory compliance - measuring return on investment. Important elements of an effective compliance program include confidential reporting and investigations. Today we speak to two subject matter experts on confidential reporting, Carrie Penman, Chief Compliance Officer of NAVE…
 
In this episode, we talk about remote witness interviews and how to make the best of a bad situation using time-tested interrogation techniques and other methods. While things are starting to return to something resembling normal, our use of video conferencing as a business tool is here to stay. I’ve been fielding a lot of questions about use of bo…
 
In this second episode of Fraud Eats Strategy, Scott Moritz speaks to Neil Barofsky, a partner at Jenner & Block and the former Special Inspector General of the Troubled Asset Relief Program about these issues. We will explore the increased discovery of financial crimes that occur in a down cycle of the economy and how organizations can use fraud r…
 
In this first episode of Fraud Eats Strategy with Scott Moritz he speaks to former Enron Whistleblower Sherron Watkins about the many red flags that were ignored, the ill-fated board decisions and the wide-ranging complicity that led to Enron’s implosion. Sherron’s memo to former Enron leadership warned of the accounting irregularities that would c…
 
In this introduction, you will meet Scott Moritz, Senior Managing Director in the Global Risk and Investigations Practice at FTI Consulting. The series features a deep dive into the various ways fraud can affect each and every one of us. Join us each week as we take a deep dive into the various forms of fraud across the world and discuss crime fami…
 
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