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Articles by Pete Viksnins
The Financial Fraud Kill Chain is the most powerful asset recovery tool you've never heard of
Recently, the FBI has been waging a highly successful but little-known campaign against sophisticated fraudsters who leverage domestic bank wire transfers to steal millions of dollars from unsuspecting victims. This campaign is possible because of a small but impactful change to the Financial Fraud Kill Chain (FFKC), a tool which, surprisingly, the FBI has not heavily publicized. Go ahead and search for it on the web.
New FinCEN Advisory on public corruption and kleptocracy targets Russia
On April 14, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued advisory FIN-2022-A001 on Kleptocracy and Foreign Public Corruption urging financial institutions “to focus efforts on detecting the proceeds of foreign public corruption, a priority for the U.S. government.” Given the extensive recent press on Russian oligarchs’ use of global financial institutions and other “gatekeepers” to transfer and secure their assets outside of Russia, it’s a timely release.
What the heck is risk-based training?
There is a portion of the DOJ’s Evaluation of Corporate Compliance Programs that has received surprisingly little play in FCPA compliance circles. Under the heading “Risk-Based Training,” the DOJ poses a series of questions companies will need to answer. What training have employees in relevant control functions received? Has the company provided tailored training for high-risk and control employees, including training that addresses risks in the area where the misconduct occurred?
HR -- yes, HR -- is the key to understanding your compliance culture
After more than two decades of forensics practice, I know that during any anti-corruption compliance assessment, I’ll want to spend time not only with personnel from the accounting and compliance groups, but also with human resources. In fact, sometimes HR receives the most attention. Here’s why. The HR team has so much impact on anti-corruption compliance because they interact with personnel from the time they are candidates all the way through to exit.
Malaysia enacts ‘global standards’ anti-corruption legislation - The FCPA Blog - The FCPA Blog
As noted in our previous post for the FCPA Blog, Malaysia passed the Malaysian Anti-Corruption Commission (Amendment) Bill 2018 last year. This amendment introduced a provision that holds corporations, and their directors, officers, and managers, potentially liable for failing to prevent acts of bribery and corruption. This development brings Malaysian anti-corruption legislation on par with global standards such as the UK Bribery Act 2010 and France’s Sapin II.
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