No Result
View All Result
SUBSCRIBE | NO FEES, NO PAYWALLS
MANAGE MY SUBSCRIPTION
NEWSLETTER
Corporate Compliance Insights
  • Home
  • About
    • About CCI
    • Writing for CCI
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Career Connection
  • Events
    • Calendar
    • Submit an Event
  • Library
    • Whitepapers & Reports
    • eBooks
    • CCI Press & Compliance Bookshelf
  • Podcasts
  • Videos
  • Subscribe
  • Home
  • About
    • About CCI
    • Writing for CCI
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Career Connection
  • Events
    • Calendar
    • Submit an Event
  • Library
    • Whitepapers & Reports
    • eBooks
    • CCI Press & Compliance Bookshelf
  • Podcasts
  • Videos
  • Subscribe
No Result
View All Result
Corporate Compliance Insights

Fraud and Bribery: Segregation of Duties

by Michael Volkov
January 27, 2016
in Uncategorized
Fraud and Bribery: Segregation of Duties

This article was republished with permission from Michael Volkov’s blog, Corruption, Crime & Compliance.

Some things go together. Chocolate chip cookies and milk, Hepburn and Tracy, Lewis and Martin (I know, I am showing my age) and many other favorite combinations. So, you get the point – in the world of anti-bribery compliance, and another in my series of profound grasps of the obvious – fraud and bribery go hand-in-hand.

One of the critical questions in assessing your company’s anti-corruption financial controls is fairly basic: what are the company’s risks of fraud? You have to obtain unauthorized access to money to fund a bribery scheme. Looking across the company, and assuming the Chief Compliance Officer is willing to get his or her hands dirty in the financial controls area, the company has to assess the overall risks of access to money for bribery.

A CCO has to look and identify potential risks of fraud, keyed to the level of risk. For example, if the company operates in China, the company should assess its internal controls in China to make sure there is adequate segregation of duties, delegations of authority, vendor on-boarding procedures and controls over payments of invoices and other payable accounts.

This inquiry grows out of a critical function in anti-corruption compliance: CCOs have to ensure that financial controls are adequately tailored to risks in geographic areas and functions. Of course, as a theoretical matter, it would be great for CCOs to ensure that financial controls are tailored to specific country or operational risks. In the ideal world, financial controls may vary across different risk areas. Unfortunately, CCOs have to be realistic about the ability of the company to tailor its financial controls to corruption risks; in most cases, such tailoring on the front end may be difficult to implement.

CCOs have to embrace an alternative strategy from a proactive design of financial controls and institute robust monitoring and auditing practices to ensure that all of the key risks of fraud are adequately mitigated.

A CCO who learns of segregation-of-duty conflicts in China has to be vigilant in monitoring such activities, pushing for remediation to eliminate the conflict and ensuring that such remediation is accomplished. CCOs have to work with internal audit and other financial managers to make sure the risk of fraud and the corresponding risk of corruption is eliminated.

If an employee has an ability to steal money from the company, the employee has the ability to steal money and use it to bribe foreign officials. Bribery cannot occur without unauthorized access to funds – in many respects theft is only the first step in a bribery scheme.

Companies have to attend to potential fraud risks. Theft is a bad thing, and it is a prerequisite for bribery. In monitoring such activities, CCOs have to partner with internal auditors and other financial managers to make sure everyone is vigilant in preventing theft and possible bribery.

Bad actors are becoming more creative in developing schemes to commit fraud. As they seek out new and more complex schemes, CCOs and financial managers have to be aware of such risks and take a moment to identify potential risks. The traditional indications are all well and good, but bad actors are enlisting other actors in a company to assist in carrying out theft.

CCOs have to educate themselves and avoid complacency. Bad actors are motivated, and CCOs have to respond accordingly.


Previous Post

EisnerAmper Publishes Board Risk Survey

Next Post

Concerns About Risks Confronting Boards

Michael Volkov

Michael Volkov

Michael-Volkov-leclairryan Michael Volkov is the CEO of The Volkov Law Group LLC, where he provides compliance, internal investigation and white collar defense services.  He can be reached at mvolkov@volkovlaw.com. Michael has extensive experience representing clients on matters involving the Foreign Corrupt Practices Act, the UK Bribery Act, money laundering, Office of Foreign Asset Control (OFAC), export controls, sanctions and International Traffic in Arms, False Claims Act, Congressional investigations, online gambling and regulatory enforcement issues. Michael served for more than 17 years as a federal prosecutor in the U.S. Attorney’s Office in the District of Columbia; for five years as the Chief Crime and Terrorism Counsel for the Senate Judiciary Committee, and Chief Crime, Terrorism and Homeland Security Counsel for the Senate and House Judiciary Committees; and as a Trial Attorney in the Antitrust Division of the U.S. Department of Justice. Michael also maintains a well-known blog: Corruption Crime & Compliance, which is frequently cited by anti-corruption professionals and professionals in the compliance industry.

Related Posts

Fox_DOJ Speeches_f

Analysis of Recent DOJ Statements

by Corporate Compliance Insights
March 23, 2023

DOJ leaders provide insight into agency's plans. Analysis of Recent Statements DOJ Shaping the Future of Corporate Criminal Enforcement What’s...

Fox_2023 ECCP Update_f

2023 Evaluation of Corporate Compliance Programs

by Corporate Compliance Insights
March 23, 2023

Keeping up with 2023 changes to DOJ guidelines. Additions, Deletions & Changes From 2020 2023 Evaluation of Corporate Compliance Programs...

encompass update

Encompass Launches pKYC Maturity Model

by Corporate Compliance Insights
March 22, 2023

KYC automation platform Encompass has unveiled a new perpetual Know Your Customer (pKYC) maturity model designed to help banks improve...

consilio onna partnership

Consilio, Onna Seek to Streamline eDiscovery for Cloud Apps

by Corporate Compliance Insights
March 22, 2023

Legal technology provider Consilio has launched a new platform, Sightline Collect, powered by data management supplier Onna. The platform is...

Next Post
Concerns About Risks Confronting Boards

Concerns About Risks Confronting Boards

Compliance Job Interview Q&A

Jump to a Topic

AML Anti-Bribery Anti-Corruption Artificial Intelligence (AI) Automation Banking Board of Directors Board Risk Oversight Business Continuity Planning California Consumer Privacy Act (CCPA) Code of Conduct Communications Management Corporate Culture COVID-19 Cryptocurrency Culture of Ethics Cybercrime Cyber Risk Data Analytics Data Breach Data Governance DOJ Download Due Diligence Enterprise Risk Management (ERM) ESG FCPA Enforcement Actions Financial Crime Financial Crimes Enforcement Network (FinCEN) GDPR HIPAA Know Your Customer (KYC) Machine Learning Monitoring RegTech Reputation Risk Risk Assessment SEC Social Media Risk Supply Chain Technology Third Party Risk Management Tone at the Top Training Whistleblowing
No Result
View All Result

Privacy Policy

Founded in 2010, CCI is the web’s premier global independent news source for compliance, ethics, risk and information security. 

Got a news tip? Get in touch. Want a weekly round-up in your inbox? Sign up for free. No subscription fees, no paywalls. 

Follow Us

Browse Topics:

  • CCI Press
  • Compliance
  • Compliance Podcasts
  • Cybersecurity
  • Data Privacy
  • eBooks Published by CCI
  • Ethics
  • FCPA
  • Featured
  • Financial Services
  • Fraud
  • Governance
  • GRC Vendor News
  • HR Compliance
  • Internal Audit
  • Leadership and Career
  • On Demand Webinars
  • Opinion
  • Resource Library
  • Risk
  • Uncategorized
  • Videos
  • Webinars
  • Well-Being
  • Whitepapers

© 2022 Corporate Compliance Insights

No Result
View All Result
  • Home
  • About
    • About CCI
    • Writing for CCI
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Career Connection
  • Events
    • Calendar
    • Submit an Event
  • Library
    • Whitepapers & Reports
    • eBooks
    • CCI Press & Compliance Bookshelf
  • Podcasts
  • Videos
  • Subscribe

© 2022 Corporate Compliance Insights

Welcome to CCI. This site uses cookies. Please click OK to accept. Privacy Policy
Cookie settingsACCEPT
Manage consent

Privacy Overview

This website uses cookies to improve your experience while you navigate through the website. Out of these, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. We also use third-party cookies that help us analyze and understand how you use this website. These cookies will be stored in your browser only with your consent. You also have the option to opt-out of these cookies. But opting out of some of these cookies may affect your browsing experience.
Necessary
Always Enabled
Necessary cookies are absolutely essential for the website to function properly. These cookies ensure basic functionalities and security features of the website, anonymously.
CookieDurationDescription
cookielawinfo-checbox-analytics11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checbox-functional11 monthsThe cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checbox-others11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-necessary11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-performance11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
viewed_cookie_policy11 monthsThe cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.
Functional
Functional cookies help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedbacks, and other third-party features.
Performance
Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.
Analytics
Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc.
Advertisement
Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. These cookies track visitors across websites and collect information to provide customized ads.
Others
Other uncategorized cookies are those that are being analyzed and have not been classified into a category as yet.
SAVE & ACCEPT