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Home Compliance

Anti-Corruption and the Hallmarks of an Effective Compliance Program: Part 9

by Scott Moritz
January 31, 2014
in Compliance
Anti-Corruption and the Hallmarks of an Effective Compliance Program: Part 9

This is the ninth in a series of articles intended to assist organizations in assessing their anti-corruption programs through the lens of the 10 hallmarks of an effective compliance program as set forth in “A Resource Guide to the U.S. Foreign Corrupt Practices Act” (“the Guide”), jointly published by the U.S. Department of Justice and the Securities and Exchange Commission in November of 2012.  This article centers on hallmark number nine:

Continuous Improvement: Periodic Testing and Review

An anti-corruption program should be a living, breathing embodiment and reflection of the current and contemplated corruption risks that are nuanced to the world at large, the industry in which the company operates and the organization’s unique characteristics – including its products and services, customer base, organizational structure and geographic footprint.

Benjamin Franklin wrote, “…in this world nothing can be said to be certain, except death and taxes.” In the business world, a third universal certainty is change. Your business will expand or contract. You will enter new markets and perhaps withdraw from others. You may acquire companies, divest parts of the company, merge or form joint ventures. You may launch new products or new lines of business. These are just a few examples of changes that may occur within your organization. But what about changes on the outside?

One ongoing phenomenon is the extent to which the DOJ and SEC in the United States and the Serious Fraud Office in the United Kingdom are looking more broadly at certain industries as part of the investigation of one or more industry participants. If you learn a competitor has a bribery problem, it is an excellent time to dust off your anti-corruption program and consider refreshing it.

Whether the changes are occurring internally, externally or both, having a mechanism to track, consider and apply those changes to your anti-corruption program will help keep your program from becoming stale and out of step with the current and emerging risks it is intended to help mitigate.

Most often, a key part of the mechanism to measure organizational performance and perform periodic testing and review is the internal audit function. As noted earlier, internal audit is on the front lines in the war on corruption. In most organizations, internal auditors are generalists. But when considered an extension of the organization’s anti-corruption program, internal audit should receive some advanced training on anti-corruption. Specifically, internal auditors should understand key concepts comprising the FCPA, the risk factors that can trigger liability, the types of red flags indicative of potential problems and the investigative steps to follow in the event they suspect a potential violation.

This article is part nine in a 10-part series exploring Anti-Corruption and the 10 Hallmarks of an Effective Compliance Program.  Each piece in the series is based on a section from a whitepaper published by Protiviti, titled “Viewing Your Anti-Corruption Efforts Through the Lens of the Hallmarks of an Effective Compliance Program,” which is available in full at:http://www.protiviti.com/en-US/Documents/White-Papers/Internal-Audit/Viewing-Anti-Corruption-Efforts-Lens-Hallmarks-Effective-Compliance-Program-Protiviti.pdf.


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Scott Moritz

Scott Moritz

Scott Moritz is a managing director at global consulting firm Protiviti Inc., where he leads the firm’s fraud, anti-corruption, and investigations practice, serving clients worldwide in a variety of industries.
A noted anticorruption strategist with more than 26 years’ experience, Moritz has been a top consultant in designing programs to help companies use risk scoring and technology to identify, investigate, and remediate high-risk relationships. He was instrumental in the development and launch of widely recognized anti-corruption platforms and due diligence products. Prior to joining Protiviti, Moritz served as a managing director for global investigations and compliance at Navigant. Before that, he spent four years as the head of the anti-corruption and investigative due diligence practice at Daylight Forensic & Advisory, which was acquired by Navigant in 2010.  Previously, Moritz also held leadership positions KPMG, LLP, in two separate instances, most recently as a director of corporate intelligence for the firm’s forensics practice.  His experience also includes senior roles at IPSA International, Inc., BDO Seidman, LLP, and PricewaterhouseCoopers, LLP. Moritz spent 10 years serving as a special agent for the Federal Bureau of Investigation (FBI), where he gained extensive experience in complex investigations of multi-national criminal investigations that included organized crime, money laundering, fraud, corruption that often involved a variety of industries such as financial services, securities, insurance, and public and private services. He was a nationally recognized expert for the FBI on asset forfeiture investigations and money laundering. Moritz graduated from the FBI Academy in Quantico, Va.  He also holds a bachelor’s degree in marketing and management from Jacksonville University.

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