Board of Directors, Caremark, Compliance, Directors, DOJ, Governance, NACD, Sarbanes-Oxley, SEC, Skepticism, White Collar Crime Jonathan T. Marks Board of Directors, Caremark, Compliance, Directors, DOJ, Governance, NACD, Sarbanes-Oxley, SEC, Skepticism, White Collar Crime Jonathan T. Marks

Ethics and Compliance: Active Board Involvement Is a Must

Establishing and supporting a corporate compliance program is widely recognized as one of the fundamental responsibilities of a corporate board of directors. But merely seeing that there is a compliance program in place is by no means an adequate effort. The Board must also actively oversee that function.
Active oversight is essential if a company’s business plan includes strategies, practices, or other elements that could be considered high-risk. Such situations call for even more involvement and active engagement by the Board.

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AMLA, Bank Secrecy Act, Board of Directors, Chief Compliance Officer, Chief Legal Counsel, Compliance, Corporate Transparency, Data, Data Analytics, Directors, DOJ, Enforcement, FinCen, Fraud and Forensic Inv..., KYC, Money Laundering, OSHA, Policies and Procedures, Risk, Risk Assessment, Risk-focused, SEC, Shell Company, Tips, Whistleblower, White Collar Crime Jonathan T. Marks AMLA, Bank Secrecy Act, Board of Directors, Chief Compliance Officer, Chief Legal Counsel, Compliance, Corporate Transparency, Data, Data Analytics, Directors, DOJ, Enforcement, FinCen, Fraud and Forensic Inv..., KYC, Money Laundering, OSHA, Policies and Procedures, Risk, Risk Assessment, Risk-focused, SEC, Shell Company, Tips, Whistleblower, White Collar Crime Jonathan T. Marks

Transparency! The New Anti-Money Laundering Act (AMLA)

On December 11, 2020, the Senate passed the Anti-Money Laundering Act of 2020 (“AMLA” or the “Act”) - DIVISION F of the National Defense Authorization Act for the fiscal year 2021 (the “NDAA”). The House of Representatives had previously passed the measure on December 8, 2020.

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10-80-10, 10-A, 3 Lines, ACFE, AICPA, Analytics, Anti-fraud, Antitrust, Audit, Audit Committee, Automation, Baker Tilly, Blockchain, Board of Directors, Books and records, Bribery, Business Intelligence, Caremark, Cash, Chief Audit Executive, Chief Compliance Officer, Chief Legal Counsel, Colleges and Universities, Collusion, Compliance, Compliance Coordinator, Conflict of Interest, Continuous Auditing, Continuous Monitoring, Control, Control Environment, Coronavirus, Corporate Fraud, Corruption, COSO, Court, COVID -19, Crisis, Crisis Management, Critical Audit Matters, Cross Border Investiga..., Cryptocurrency, Culture, Culture Assessment, Cyber, Damages, Data, Data Analytics, Data Integrity, Directors, Disclosure, Dodd Frank, Dodd-Frank, DOJ, Due Diligence, Dunning Kruger, Enforcement, Enterprise Risk Resili..., Enterprise Risk Resili..., EQS, ERM, Ethics, Evidence, Exit Interview, Fake Invoices, False Claims Act, FCPA, Federal Sentencing Gui..., Financial reporting an..., FinCen, Food Safety, Foreign Corrupt Practi..., Forensic Accounting, Forensically Speaking, Four eyes approval, Fraud, Fraud and Forensic, Fraud and Forensic Inv..., Fraud Investigations, Fraud Pentagon, Fraud Risk Management, Fraud Task Force, Fraud Triangle, GAAP, GDPR, General Counsel, Gifts, Global, Governance, GRC, Guidance, Hidden Assets, Hotline, IDORP, IIA, IIA Philadelphia, IIOT, Impairment, Initial Coin Offering, Insider Trading, Internal Audit, Internal Control Defic..., Internal Controls, Interview, Investigations, Jonathan T- Marks, Judgment and Estimates, Keyword, Kickbacks, Leadership, Legal, Lessons Learned, Management Override, Materiality, MD&A, Money Laundering, Monitor, Monitoring, Monitorship, NACD, Nonprofit, Not for Profit, OFAC, Office of Foreign Asse..., Oversight, Phishing, Podcast, Policies and Procedures, Process Improvement, Proxy, Qui Tam, ransom, Ransomeware, Red Flag, RegTech, Regulatory, Related Party, Remediation, Remote Internal Invest..., Remote Investigations, Reputation, Restatement, Risk, Risk Assessment, Risk factors, Risk Management, Robotic, Root Cause, Sampling, Sarbanes-Oxley, Seaboard, SEC, Shell Company, Skepticism, Slush Fund, Supreme Court, Tax, Tax Fraud, Technology, Theft, Third Party, Thought Leadership, Three Lines, Three Lines of Defense, Tips, tone at the top, Tone from the Top, Training, Treasury, Triage, Uncategorized, Values, Webinar, Whistleblower, White Collar Crime, Yellow Flag Jonathan T. Marks 10-80-10, 10-A, 3 Lines, ACFE, AICPA, Analytics, Anti-fraud, Antitrust, Audit, Audit Committee, Automation, Baker Tilly, Blockchain, Board of Directors, Books and records, Bribery, Business Intelligence, Caremark, Cash, Chief Audit Executive, Chief Compliance Officer, Chief Legal Counsel, Colleges and Universities, Collusion, Compliance, Compliance Coordinator, Conflict of Interest, Continuous Auditing, Continuous Monitoring, Control, Control Environment, Coronavirus, Corporate Fraud, Corruption, COSO, Court, COVID -19, Crisis, Crisis Management, Critical Audit Matters, Cross Border Investiga..., Cryptocurrency, Culture, Culture Assessment, Cyber, Damages, Data, Data Analytics, Data Integrity, Directors, Disclosure, Dodd Frank, Dodd-Frank, DOJ, Due Diligence, Dunning Kruger, Enforcement, Enterprise Risk Resili..., Enterprise Risk Resili..., EQS, ERM, Ethics, Evidence, Exit Interview, Fake Invoices, False Claims Act, FCPA, Federal Sentencing Gui..., Financial reporting an..., FinCen, Food Safety, Foreign Corrupt Practi..., Forensic Accounting, Forensically Speaking, Four eyes approval, Fraud, Fraud and Forensic, Fraud and Forensic Inv..., Fraud Investigations, Fraud Pentagon, Fraud Risk Management, Fraud Task Force, Fraud Triangle, GAAP, GDPR, General Counsel, Gifts, Global, Governance, GRC, Guidance, Hidden Assets, Hotline, IDORP, IIA, IIA Philadelphia, IIOT, Impairment, Initial Coin Offering, Insider Trading, Internal Audit, Internal Control Defic..., Internal Controls, Interview, Investigations, Jonathan T- Marks, Judgment and Estimates, Keyword, Kickbacks, Leadership, Legal, Lessons Learned, Management Override, Materiality, MD&A, Money Laundering, Monitor, Monitoring, Monitorship, NACD, Nonprofit, Not for Profit, OFAC, Office of Foreign Asse..., Oversight, Phishing, Podcast, Policies and Procedures, Process Improvement, Proxy, Qui Tam, ransom, Ransomeware, Red Flag, RegTech, Regulatory, Related Party, Remediation, Remote Internal Invest..., Remote Investigations, Reputation, Restatement, Risk, Risk Assessment, Risk factors, Risk Management, Robotic, Root Cause, Sampling, Sarbanes-Oxley, Seaboard, SEC, Shell Company, Skepticism, Slush Fund, Supreme Court, Tax, Tax Fraud, Technology, Theft, Third Party, Thought Leadership, Three Lines, Three Lines of Defense, Tips, tone at the top, Tone from the Top, Training, Treasury, Triage, Uncategorized, Values, Webinar, Whistleblower, White Collar Crime, Yellow Flag Jonathan T. Marks

2020 Top 10 Articles on Fraud, Compliance, and Risk Management

Happy New Year, and thank you to the more than 100,000 people that visited Board and Fraud in 2020!
With everything that happened last year, fraud, compliance, and risk management have arguably become more important than ever.

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Anti-fraud, Audit Committee, Chief Audit Executive, Chief Compliance Officer, Compliance, Corporate Fraud, COVID -19, Crisis, Crisis Management, Directors, DOJ, Fraud, Fraud and Forensic, Fraud and Forensic Inv..., Fraud Investigations, Fraud Risk Management, General Counsel, Governance, Investigations, Jonathan T- Marks, Risk, Risk Assessment, White Collar Crime Jonathan T. Marks Anti-fraud, Audit Committee, Chief Audit Executive, Chief Compliance Officer, Compliance, Corporate Fraud, COVID -19, Crisis, Crisis Management, Directors, DOJ, Fraud, Fraud and Forensic, Fraud and Forensic Inv..., Fraud Investigations, Fraud Risk Management, General Counsel, Governance, Investigations, Jonathan T- Marks, Risk, Risk Assessment, White Collar Crime Jonathan T. Marks

COVID-19 - Fraud On The Rise is No Surprise!

Last week, the Association of Certified Fraud Examiners (” ACFE”) published the results of a survey taken by more than 1,800 anti-fraud professionals in late April and early May 2020, while we were deep into the Covid-19 crisis.  The findings, for the most part, are not surprising, but does reveal some disappointing information.  While I have not seen a raw copy of the survey, I was surprised the ACFE didn’t ask if the company’s fraud risk assessment was reviewed and modified accordingly.In addition, the survey highlights trends in the overall level of fraud. Survey respondents provided information about their current observations and expected changes regarding ten (10) specific types of fraud.

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ACFE, Audit Committee, Board of Directors, Chief Audit Executive, Chief Compliance Officer, Compliance, Compliance Coordinator, Corporate Fraud, Crisis, Crisis Management, Directors, Dodd Frank, Dodd-Frank, DOJ, Ethics, Fraud, Fraud and Forensic, Fraud and Forensic Inv..., Fraud Risk Management, Governance, Internal Audit, Internal Controls, Investigations, Money Laundering, Risk, Risk Management, Root Cause, SEC, Tone from the Top, Triage, Whistleblower, White Collar Crime Jonathan T. Marks ACFE, Audit Committee, Board of Directors, Chief Audit Executive, Chief Compliance Officer, Compliance, Compliance Coordinator, Corporate Fraud, Crisis, Crisis Management, Directors, Dodd Frank, Dodd-Frank, DOJ, Ethics, Fraud, Fraud and Forensic, Fraud and Forensic Inv..., Fraud Risk Management, Governance, Internal Audit, Internal Controls, Investigations, Money Laundering, Risk, Risk Management, Root Cause, SEC, Tone from the Top, Triage, Whistleblower, White Collar Crime Jonathan T. Marks

Whistleblowers: Tipsters not trusting the system?

Whistleblowers: Tipsters not trusting the system? Here's how to win them back.Anonymous hotlines and tip-reporting structures are useless, of course, if informants don’t trust them. Employees won’t blow the whistle if they fear reprisals. So, their concerns often don’t enter case-management systems and frauds continue. Here’s how to earn back their trust, take them seriously and transform raw tips into valuable fraud examinations.Ovem lupo commitere!

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Anti-fraud, Audit, Audit Committee, Board of Directors, Books and records, Conflict of Interest, Corporate Fraud, Culture, Damages, Directors, Evidence, Forensic Accounting, Fraud, Fraud Investigations, Fraud Risk Management, General Counsel, Governance, GRC, Investigations, Monitor, Nonprofit, Not for Profit, Process Improvement, Red Flag, Related Party, Risk, Risk Assessment, Risk Management, Sarbanes-Oxley, Skepticism, Theft, Tips, Whistleblower, White Collar Crime Jonathan T. Marks Anti-fraud, Audit, Audit Committee, Board of Directors, Books and records, Conflict of Interest, Corporate Fraud, Culture, Damages, Directors, Evidence, Forensic Accounting, Fraud, Fraud Investigations, Fraud Risk Management, General Counsel, Governance, GRC, Investigations, Monitor, Nonprofit, Not for Profit, Process Improvement, Red Flag, Related Party, Risk, Risk Assessment, Risk Management, Sarbanes-Oxley, Skepticism, Theft, Tips, Whistleblower, White Collar Crime Jonathan T. Marks

A Violation of Trust: Fraud Risk in Nonprofit or Not-for Profit Organizations

The risk of fraud is a serious concern for all types of enterprises, but fraud can be particularly damaging to a nonprofit or not-for-profit organization, for which a damaged reputation can have devastating consequences.

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Audit Committee, Baker Tilly, Board of Directors, Bribery, Caremark, Chief Compliance Officer, Compliance, Compliance Coordinator, Corporate Fraud, Directors, Fraud and Forensic Inv..., Fraud Risk Management, Governance, GRC, Regulatory, Risk Jonathan T. Marks Audit Committee, Baker Tilly, Board of Directors, Bribery, Caremark, Chief Compliance Officer, Compliance, Compliance Coordinator, Corporate Fraud, Directors, Fraud and Forensic Inv..., Fraud Risk Management, Governance, GRC, Regulatory, Risk Jonathan T. Marks

The Role of the Board of Directors in Compliance Oversight

Under the U.S. Federal Sentencing Guidelines, in order to receive credit for having an effective compliance program, and thereby reduce the fines imposed on the organization, a Board of Directors must be “knowledgeable about the content and operation of the compliance and ethics program,” and must “exercise reasonable oversight with respect to the implementation and effectiveness of the compliance and ethics program.” In addition, in criminal actions against a business organization, including the FCPA, the DOJ’s Justice Manual instructs prosecutors to ask and answer several questions, including: 1) Do the Directors exercise independent review of the company’s compliance program? and 2) Are Directors provided timely and accurate information sufficient to enable the exercise of independent judgment?

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Audit Committee, Board of Directors, Chief Compliance Officer, Compliance, Directors, Fraud and Forensic Inv..., General Counsel, Legal, Regulatory Jonathan T. Marks Audit Committee, Board of Directors, Chief Compliance Officer, Compliance, Directors, Fraud and Forensic Inv..., General Counsel, Legal, Regulatory Jonathan T. Marks

The Compliance Shift - Now for Tomorrow!

Where is compliance headed in the 2020’s? Certainly, technological solutions will be a big part of the future of compliance programs and controls. Compliance is rapidly emerging and being viewed as a critical business process. Moving away from the days in which it was driven by legalese and where lawyers are responsible for crafting compliance policies and procedures.  These advances provide opportunity for innovation, and enable compliance to recede from being viewed as a cost center led by the “head of business denial”, to being viewed as value added function to the business. Simply put, a more effective compliance program contributes to more efficient business processes, which leads to greater profitability.

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Anti-fraud, Audit Committee, Baker Tilly, Bribery, Chief Audit Executive, Chief Compliance Officer, Coronavirus, Corporate Fraud, COVID -19, Crisis Management, Directors, Ethics, FCPA, Foreign Corrupt Practi..., Fraud, Fraud and Forensic Inv..., Fraud Investigations, Fraud Pentagon, Fraud Risk Management, General Counsel, Governance, Hotline, IIA, Internal Audit, Investigations, Management Override, Phishing, Risk factors, Risk Management, White Collar Crime Jonathan T. Marks Anti-fraud, Audit Committee, Baker Tilly, Bribery, Chief Audit Executive, Chief Compliance Officer, Coronavirus, Corporate Fraud, COVID -19, Crisis Management, Directors, Ethics, FCPA, Foreign Corrupt Practi..., Fraud, Fraud and Forensic Inv..., Fraud Investigations, Fraud Pentagon, Fraud Risk Management, General Counsel, Governance, Hotline, IIA, Internal Audit, Investigations, Management Override, Phishing, Risk factors, Risk Management, White Collar Crime Jonathan T. Marks

Fraud, Compliance & Integrity Risk During a Crisis and a Downturn

As a crisis unfolds, like Coronavirus, and markets decline globally, fraudsters will be adapting and new risks will emerge and some risks will increase. Remember, white collar criminals adapt by profiling us, so they can exploit our weaknesses. That being said, companies need to develop a strategy that enables the deployment of appropriate tactics to manage these new or increasing risks.This writing explores some fraud, compliance, and integrity risks and is intended to provoke discussion.

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Anti-fraud, Audit, Audit Committee, Baker Tilly, Chief Audit Executive, Chief Compliance Officer, Compliance, Compliance Coordinator, Corporate Fraud, Corruption, Culture, Culture Assessment, Data Analytics, Directors, DOJ, Ethics, FCPA, Forensic Accounting, Fraud and Forensic, Fraud Investigations, Fraud Pentagon, Fraud Risk Management, General Counsel, Global, Governance, IIA, IIA Philadelphia, Internal Audit, Internal Control Defic..., Internal Controls, Investigations, Jonathan T- Marks, Management Override, Money Laundering, Policies and Procedures, Process Improvement, Red Flag, Regulatory, Risk, Risk Assessment, Risk Management, Root Cause, Sarbanes-Oxley, SEC, Technology, Theft, Third Party, Tone from the Top, Training, Triage, Values, White Collar Crime Jonathan T. Marks Anti-fraud, Audit, Audit Committee, Baker Tilly, Chief Audit Executive, Chief Compliance Officer, Compliance, Compliance Coordinator, Corporate Fraud, Corruption, Culture, Culture Assessment, Data Analytics, Directors, DOJ, Ethics, FCPA, Forensic Accounting, Fraud and Forensic, Fraud Investigations, Fraud Pentagon, Fraud Risk Management, General Counsel, Global, Governance, IIA, IIA Philadelphia, Internal Audit, Internal Control Defic..., Internal Controls, Investigations, Jonathan T- Marks, Management Override, Money Laundering, Policies and Procedures, Process Improvement, Red Flag, Regulatory, Risk, Risk Assessment, Risk Management, Root Cause, Sarbanes-Oxley, SEC, Technology, Theft, Third Party, Tone from the Top, Training, Triage, Values, White Collar Crime Jonathan T. Marks

IIA Philadelphia and Baker Tilly’s Fraud & Ethics Symposium is Postponed! Stay tuned for the new date.

This one-day fraud symposium, sponsored by Baker Tilly's Global Forensic, Compliance and Integrity Services, and Solutions Practice Group and hosted by the Institute of Internal Auditors, Philadelphia Chapter, will include topics such as:•Culture•Current trends in white-collar crime•Tone is the middle•Policy management•Case study on a local fraudDiscover who will be speaking and register for the event!

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Anti-fraud, Audit Committee, Baker Tilly, Board of Directors, Books and records, Bribery, Chief Audit Executive, Chief Compliance Officer, Compliance, Control Environment, Corporate Fraud, Corruption, Culture, Directors, DOJ, Ethics, FCPA, Foreign Corrupt Practi..., Forensic Accounting, Fraud and Forensic Inv..., Fraud Investigations, Fraud Risk Management, General Counsel, Global, Governance, Internal Audit, Internal Control Defic..., Internal Controls, Investigations, Management Override, Policies and Procedures, Process Improvement, Red Flag, Risk, Risk Assessment, Risk Management, SEC, Tone from the Top, Training, White Collar Crime Jonathan T. Marks Anti-fraud, Audit Committee, Baker Tilly, Board of Directors, Books and records, Bribery, Chief Audit Executive, Chief Compliance Officer, Compliance, Control Environment, Corporate Fraud, Corruption, Culture, Directors, DOJ, Ethics, FCPA, Foreign Corrupt Practi..., Forensic Accounting, Fraud and Forensic Inv..., Fraud Investigations, Fraud Risk Management, General Counsel, Global, Governance, Internal Audit, Internal Control Defic..., Internal Controls, Investigations, Management Override, Policies and Procedures, Process Improvement, Red Flag, Risk, Risk Assessment, Risk Management, SEC, Tone from the Top, Training, White Collar Crime Jonathan T. Marks

Fraud Tip Friday: Lessons From Recent FCPA Enforcement Actions

The United States government’s fiscal year ended on September 30, 2019. Just as in the business world, where many companies try and clear out any unexecuted deals or open contracts, the Securities and Exchange Commission (SEC) cleared out three outstanding Foreign Corrupt Practices Act (FCPA) enforcement actions. The three enforcement actions involved Quad/Graphics Inc., a Wisconsin-based digital and print marketing provider, and its Peruvian subsidiary, Quad/Graphics Peru S.A.; Barclays PLC; and a Canadian clean fuel company Westport Fuels Systems, Inc. and its former Chief Executive Officer (CEO), Nancy Gougarty of Leesville, South Carolina. The terms of each settlement agreement provide a different lesson for compliance practitioners.

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ACFE, Analytics, Anti-fraud, Audit, Audit Committee, Automation, Baker Tilly, Board of Directors, Books and records, Bribery, Caremark, Cash, Chief Audit Executive, Chief Compliance Officer, Colleges and Universities, Collusion, Compliance, Compliance Coordinator, Conflict of Interest, Continuous Monitoring, Control Environment, Corporate Fraud, Corruption, COSO, Court, Crisis Management, Critical Audit Matters, Cross Border Investiga..., Culture, Culture Assessment, Cyber, Damages, Data, Data Analytics, Data Integrity, Directors, Dodd Frank, Dodd-Frank, DOJ, Due Diligence, ERM, Ethics, Evidence, False Claims Act, FCPA, Foreign Corrupt Practi..., Forensic Accounting, Four eyes approval, Fraud, Fraud and Forensic, Fraud Investigations, Fraud Pentagon, Fraud Risk Management, Fraud Triangle, GDPR, General Counsel, Global, Governance, GRC, Hidden Assets, Hotline, IIA, IIA Philadelphia, IIOT, Internal Audit, Internal Control Defic..., Internal Controls, Interview, Investigations, Jonathan T- Marks, Management Override, Materiality, Money Laundering, Monitor, Monitoring, Monitorship, NACD, Nonprofit, Not for Profit, Phishing, Podcast, Policies and Procedures, Process Improvement, Proxy, Qui Tam, Red Flag, RegTech, Regulatory, Related Party, Remediation, Reputation, Restatement, Risk, Risk Assessment, Risk Management, Robotic, Root Cause, Sampling, Sarbanes-Oxley, Seaboard, SEC, Shell Company, Skepticism, Slush Fund, Supreme Court, Tax, Tax Fraud, Technology, Theft, Third Party, Thought Leadership, Tips, Tone from the Top, Training, Treasury, Triage, Uncategorized, Values, Whistleblower, White Collar Crime, Yellow Flag Jonathan T. Marks ACFE, Analytics, Anti-fraud, Audit, Audit Committee, Automation, Baker Tilly, Board of Directors, Books and records, Bribery, Caremark, Cash, Chief Audit Executive, Chief Compliance Officer, Colleges and Universities, Collusion, Compliance, Compliance Coordinator, Conflict of Interest, Continuous Monitoring, Control Environment, Corporate Fraud, Corruption, COSO, Court, Crisis Management, Critical Audit Matters, Cross Border Investiga..., Culture, Culture Assessment, Cyber, Damages, Data, Data Analytics, Data Integrity, Directors, Dodd Frank, Dodd-Frank, DOJ, Due Diligence, ERM, Ethics, Evidence, False Claims Act, FCPA, Foreign Corrupt Practi..., Forensic Accounting, Four eyes approval, Fraud, Fraud and Forensic, Fraud Investigations, Fraud Pentagon, Fraud Risk Management, Fraud Triangle, GDPR, General Counsel, Global, Governance, GRC, Hidden Assets, Hotline, IIA, IIA Philadelphia, IIOT, Internal Audit, Internal Control Defic..., Internal Controls, Interview, Investigations, Jonathan T- Marks, Management Override, Materiality, Money Laundering, Monitor, Monitoring, Monitorship, NACD, Nonprofit, Not for Profit, Phishing, Podcast, Policies and Procedures, Process Improvement, Proxy, Qui Tam, Red Flag, RegTech, Regulatory, Related Party, Remediation, Reputation, Restatement, Risk, Risk Assessment, Risk Management, Robotic, Root Cause, Sampling, Sarbanes-Oxley, Seaboard, SEC, Shell Company, Skepticism, Slush Fund, Supreme Court, Tax, Tax Fraud, Technology, Theft, Third Party, Thought Leadership, Tips, Tone from the Top, Training, Treasury, Triage, Uncategorized, Values, Whistleblower, White Collar Crime, Yellow Flag Jonathan T. Marks

Speaking and Training on Fraud, Compliance, Ethics, and More...

Welcome to my site. I have spoken and been the keynote speaker for many conferences, including the ABA, ACC, ACFE, IIA, and IMA to name a few. I have designed customized training for the board, senior leadership, legal, compliance, internal audit, and others for some of the world's largest organizations.

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Anti-fraud, Audit, Audit Committee, Baker Tilly, Bribery, Chief Audit Executive, Chief Compliance Officer, Corporate Fraud, Corruption, Data, Data Analytics, Data Integrity, Directors, DOJ, Due Diligence, ERM, Ethics, FCPA, Foreign Corrupt Practi..., Forensic Accounting, Fraud, Fraud and Forensic, Fraud Investigations, Fraud Pentagon, Fraud Risk Management, General Counsel, Governance, Internal Audit, Internal Control Defic..., Internal Controls, Management Override, Policies and Procedures, Risk, Risk Assessment, Risk Management, Whistleblower, White Collar Crime Jonathan T. Marks Anti-fraud, Audit, Audit Committee, Baker Tilly, Bribery, Chief Audit Executive, Chief Compliance Officer, Corporate Fraud, Corruption, Data, Data Analytics, Data Integrity, Directors, DOJ, Due Diligence, ERM, Ethics, FCPA, Foreign Corrupt Practi..., Forensic Accounting, Fraud, Fraud and Forensic, Fraud Investigations, Fraud Pentagon, Fraud Risk Management, General Counsel, Governance, Internal Audit, Internal Control Defic..., Internal Controls, Management Override, Policies and Procedures, Risk, Risk Assessment, Risk Management, Whistleblower, White Collar Crime Jonathan T. Marks

Fraud: Department of Justice (DOJ) Announces Procurement Collusion Strike Force

On November 5th, the Department of Justice announced the formation of the new Procurement Collusion Strike Force (PCSF) “focusing on deterring, detecting, investigating and prosecuting antitrust crimes, such as bid-rigging conspiracies and related fraudulent schemes, which undermine competition in government procurement, grant and program funding”.The Strike Force is an inter-agency partnership comprised of prosecutors from the Antitrust Division, and prosecutors from thirteen (13) U.S. Attorneys’ Offices.  Aiding in the prosecutors’ efforts are investigation partners such as the Offices of Inspector Generals from the Department of Justice, Department of Defense, U.S. Postal Service, and General Services Administration Office. The Department of Justice’s announcement proclaimed that investigating and prosecuting those who “cheat, collude and seek to undermine the integrity of government procurement” will have more to concern themselves with when executing their crimes. Prosecutors and investigators alike expressed enthusiasm to be working as a part of this new team.

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Anti-fraud, Audit Committee, Board of Directors, Chief Audit Executive, Chief Compliance Officer, Compliance, Corporate Fraud, Directors, Ethics, Evidence, FCPA, Foreign Corrupt Practi..., Forensic Accounting, Fraud, Fraud Pentagon, Fraud Risk Management, General Counsel, Governance, Internal Audit, Internal Control Defic..., Internal Controls, Investigations, NACD, Red Flag, Risk, Risk Assessment, Risk Management, Root Cause, Sarbanes-Oxley, SEC, Skepticism, Tips, Tone from the Top, Training, Values, White Collar Crime, Yellow Flag Jonathan T. Marks Anti-fraud, Audit Committee, Board of Directors, Chief Audit Executive, Chief Compliance Officer, Compliance, Corporate Fraud, Directors, Ethics, Evidence, FCPA, Foreign Corrupt Practi..., Forensic Accounting, Fraud, Fraud Pentagon, Fraud Risk Management, General Counsel, Governance, Internal Audit, Internal Control Defic..., Internal Controls, Investigations, NACD, Red Flag, Risk, Risk Assessment, Risk Management, Root Cause, Sarbanes-Oxley, SEC, Skepticism, Tips, Tone from the Top, Training, Values, White Collar Crime, Yellow Flag Jonathan T. Marks

Skepticism - A Key Tool in the Fight Against Fraud

“Trust but verify” could be a downright dangerous approach when applied to audit procedures in particular. A much better slogan for fraud deterrence would be, “Trust is a professional hazard.”The implication is that because financial management plays a leading role in detecting financial fraud, it is incumbent on executives – not just auditors – to exercise appropriate levels of professional skepticism. Board members and particularly audit committee members also must take care to exercise a skeptical approach to financial reports and supporting information.

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Anti-fraud, Audit Committee, Board of Directors, Books and records, Bribery, Compliance, Compliance Coordinator, Corporate Fraud, Corruption, Directors, DOJ, ERM, Ethics, FCPA, Foreign Corrupt Practi..., Forensic Accounting, Four eyes approval, Fraud, Fraud and Forensic, Fraud Investigations, Fraud Risk Management, General Counsel, Global, Governance, Internal Audit, Internal Control Defic..., Internal Controls, Investigations, Monitor, Regulatory, SEC, Slush Fund, Triage, Whistleblower, White Collar Crime Jonathan T. Marks Anti-fraud, Audit Committee, Board of Directors, Books and records, Bribery, Compliance, Compliance Coordinator, Corporate Fraud, Corruption, Directors, DOJ, ERM, Ethics, FCPA, Foreign Corrupt Practi..., Forensic Accounting, Four eyes approval, Fraud, Fraud and Forensic, Fraud Investigations, Fraud Risk Management, General Counsel, Global, Governance, Internal Audit, Internal Control Defic..., Internal Controls, Investigations, Monitor, Regulatory, SEC, Slush Fund, Triage, Whistleblower, White Collar Crime Jonathan T. Marks

Slush Funds and the Juniper Networks FCPA Settlement

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ACFE, Anti-fraud, Audit, Audit Committee, Board of Directors, Books and records, Bribery, Chief Audit Executive, Chief Compliance Officer, Collusion, Compliance, Compliance Coordinator, Control Environment, Corporate Fraud, Crisis Management, Cross Border Investiga..., Damages, Directors, Dodd Frank, DOJ, ERM, Ethics, False Claims Act, FCPA, Foreign Corrupt Practi..., Forensic Accounting, Fraud, Fraud and Forensic, Fraud Investigations, Fraud Pentagon, Fraud Risk Management, General Counsel, Governance, Hotline, IIA, IIA Philadelphia, Internal Audit, Internal Controls, Investigations, Money Laundering, Monitoring, Process Improvement, Red Flag, Regulatory, Risk, Risk Assessment, Risk Management, Root Cause, Sarbanes-Oxley, SEC, Shell Company, Thought Leadership, Tone from the Top, Training, Triage, Values, Whistleblower, White Collar Crime Jonathan T. Marks ACFE, Anti-fraud, Audit, Audit Committee, Board of Directors, Books and records, Bribery, Chief Audit Executive, Chief Compliance Officer, Collusion, Compliance, Compliance Coordinator, Control Environment, Corporate Fraud, Crisis Management, Cross Border Investiga..., Damages, Directors, Dodd Frank, DOJ, ERM, Ethics, False Claims Act, FCPA, Foreign Corrupt Practi..., Forensic Accounting, Fraud, Fraud and Forensic, Fraud Investigations, Fraud Pentagon, Fraud Risk Management, General Counsel, Governance, Hotline, IIA, IIA Philadelphia, Internal Audit, Internal Controls, Investigations, Money Laundering, Monitoring, Process Improvement, Red Flag, Regulatory, Risk, Risk Assessment, Risk Management, Root Cause, Sarbanes-Oxley, SEC, Shell Company, Thought Leadership, Tone from the Top, Training, Triage, Values, Whistleblower, White Collar Crime Jonathan T. Marks

Niki A. den Nieuwenboer will be kicking off the 2020 IIA Philly Fraud Symposium sponsored by Baker Tilly - Mark your calendars for March 20th!

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Audit Committee, Board of Directors, Chief Compliance Officer, Compliance, Corporate Fraud, Corruption, Crisis Management, Cross Border Investiga..., Directors, Dodd Frank, Dodd-Frank, DOJ, ERM, Ethics, False Claims Act, FCPA, Food Safety, Foreign Corrupt Practi..., Forensic Accounting, Fraud, Fraud and Forensic, Fraud Investigations, Fraud Risk Management, GDPR, General Counsel, Governance, Hotline, IIA, Internal Audit, Internal Control Defic..., Internal Controls, Interview, Investigations, Money Laundering, NACD, Nonprofit, Process Improvement, Qui Tam, Red Flag, Regulatory, Restatement, Risk, Risk Assessment, Risk Management, Root Cause, Sarbanes-Oxley, SEC, Skepticism, Tone from the Top, Training, Triage, Whistleblower, White Collar Crime, Yellow Flag Jonathan T. Marks Audit Committee, Board of Directors, Chief Compliance Officer, Compliance, Corporate Fraud, Corruption, Crisis Management, Cross Border Investiga..., Directors, Dodd Frank, Dodd-Frank, DOJ, ERM, Ethics, False Claims Act, FCPA, Food Safety, Foreign Corrupt Practi..., Forensic Accounting, Fraud, Fraud and Forensic, Fraud Investigations, Fraud Risk Management, GDPR, General Counsel, Governance, Hotline, IIA, Internal Audit, Internal Control Defic..., Internal Controls, Interview, Investigations, Money Laundering, NACD, Nonprofit, Process Improvement, Qui Tam, Red Flag, Regulatory, Restatement, Risk, Risk Assessment, Risk Management, Root Cause, Sarbanes-Oxley, SEC, Skepticism, Tone from the Top, Training, Triage, Whistleblower, White Collar Crime, Yellow Flag Jonathan T. Marks

Jonathan T. Marks, Baker Tilly Partner, is Speaking Today at the First Chair Event in Chicago on Triaging Whistleblower Allegations

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