Audit Committee, Board of Directors, Chief Compliance Officer, Compliance, FCPA, Foreign Corrupt Practi..., Fraud, Fraud and Forensic Inv..., Fraud Risk Management, General Counsel, Governance, Internal Audit, Internal Controls, Risk, White Collar Crime Jonathan T. Marks Audit Committee, Board of Directors, Chief Compliance Officer, Compliance, FCPA, Foreign Corrupt Practi..., Fraud, Fraud and Forensic Inv..., Fraud Risk Management, General Counsel, Governance, Internal Audit, Internal Controls, Risk, White Collar Crime Jonathan T. Marks

FCPA - The Role of The Board and More!

One of the FCPA themes for 2020 has been hiding in plain sight all along. The FCPA requirement that “reporting companies to devise and maintain a system of internal accounting controls sufficient to provide reasonable assurances that, among other things, transactions are executed following management’s general or specific authorizations, and access to assets is permitted only in accordance with management’s general or specific authorization.” But what if the violation of this requirement occurs in a non-foreign (IE., the U.S.) and in a non-bribery situation.

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DOJ, Ethics, FCPA, Foreign Corrupt Practi..., Fraud and Forensic Inv..., Global, Risk, SEC, Whistleblower, White Collar Crime Jonathan T. Marks DOJ, Ethics, FCPA, Foreign Corrupt Practi..., Fraud and Forensic Inv..., Global, Risk, SEC, Whistleblower, White Collar Crime Jonathan T. Marks

Red Flags That May Indicate You Might be at Risk of Violating FCPA

In 2020, the DOJ and SEC brought FCPA enforcement actions against 12 companies and imposed financial penalties totaling a record $6.4 billion. For a comparison, in 2019, 14 companies paid a (then) record $2.9 billion to resolve FCPA cases.Are you exposed?

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ACFE, AICPA, Anti-fraud, Baker Tilly, Bank Secrecy Act, Board of Directors, Books and records, Bribery, Business Intelligence, Compliance, Culture, Disclosure, Dodd-Frank, DOJ, Enforcement, Enterprise Risk Resili..., Ethics, Evidence, False Claims Act, FCPA, Federal Sentencing Gui..., Foreign Corrupt Practi..., Forensic Accounting, Forensically Speaking, Fraud and Forensic, Fraud and Forensic Inv..., Fraud Investigations, Fraud Pentagon, Fraud Risk Management, Fraud Task Force, General Counsel, Governance, GRC, Hotline, IIA, Internal Audit, Internal Control Defic..., Internal Controls, Jonathan T- Marks, Kickbacks, KYC, Leadership, Legal, Management Override, Money Laundering, Monitoring, NACD, Not for Profit, OFAC, Policies and Procedures, Process Improvement, Qui Tam, RegTech, Regulatory, Remediation, Remote Internal Invest..., Remote Investigations, Risk Assessment, Risk factors, Risk Management, Risk-focused, Root Cause, Sarbanes-Oxley, SEC, Third Party, Thought Leadership, Webinar, Whistleblower, White Collar Crime Jonathan T. Marks ACFE, AICPA, Anti-fraud, Baker Tilly, Bank Secrecy Act, Board of Directors, Books and records, Bribery, Business Intelligence, Compliance, Culture, Disclosure, Dodd-Frank, DOJ, Enforcement, Enterprise Risk Resili..., Ethics, Evidence, False Claims Act, FCPA, Federal Sentencing Gui..., Foreign Corrupt Practi..., Forensic Accounting, Forensically Speaking, Fraud and Forensic, Fraud and Forensic Inv..., Fraud Investigations, Fraud Pentagon, Fraud Risk Management, Fraud Task Force, General Counsel, Governance, GRC, Hotline, IIA, Internal Audit, Internal Control Defic..., Internal Controls, Jonathan T- Marks, Kickbacks, KYC, Leadership, Legal, Management Override, Money Laundering, Monitoring, NACD, Not for Profit, OFAC, Policies and Procedures, Process Improvement, Qui Tam, RegTech, Regulatory, Remediation, Remote Internal Invest..., Remote Investigations, Risk Assessment, Risk factors, Risk Management, Risk-focused, Root Cause, Sarbanes-Oxley, SEC, Third Party, Thought Leadership, Webinar, Whistleblower, White Collar Crime Jonathan T. Marks

Still time to join us on February 23-25! Baker Tilly’s 1st Annual Virtual Fraud and Compliance Summit

We are introducing our first annual virtual Baker Tilly Fraud and Compliance Summit, hosted by Jonathan T. Marks, who leads Baker Tilly’s Global Forensic, Compliance, and Integrity Services Practice.

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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, Board of Directors, Chief Audit Executive, Chief Compliance Officer, Chief Legal Counsel, DOJ, Enterprise Risk Resili..., Fake Invoices, Foreign Corrupt Practi..., Forensic Accounting, Fraud, Fraud and Forensic, Fraud and Forensic Inv..., Fraud Investigations, General Counsel, Internal Audit, Kickbacks, Money Laundering, Red Flag, Shell Company, White Collar Crime Jonathan T. Marks Anti-fraud, Audit Committee, Board of Directors, Chief Audit Executive, Chief Compliance Officer, Chief Legal Counsel, DOJ, Enterprise Risk Resili..., Fake Invoices, Foreign Corrupt Practi..., Forensic Accounting, Fraud, Fraud and Forensic, Fraud and Forensic Inv..., Fraud Investigations, General Counsel, Internal Audit, Kickbacks, Money Laundering, Red Flag, Shell Company, White Collar Crime Jonathan T. Marks

DOJ Unravels a Decade-Old Scheme that involved Kickbacks, Money Laundering, Sham Shell Companies, and Fake Invoices

According to evidence presented at trial, Aleksandr Pikus, 45, of Brooklyn, New York, and his co-conspirators perpetrated a scheme through a series of medical clinics in Brooklyn and Queens over nearly a decade.   The clinics employed doctors, physical and occupational therapists, and other medical professionals who were enrolled in the Medicare and Medicaid programs.  In return for illegal kickbacks, Pikus referred beneficiaries to these health care providers, who submitted claims to the Medicare and Medicaid programs.Pikus and his co-conspirators then laundered a substantial portion of the proceeds of these claims through companies he controlled, including by cashing checks at several New York City check-cashing businesses.  Pikus then failed to report that cash income to the IRS.  Instead, Pikus used the cash to enrich himself and others and to pay kickbacks to patient recruiters, who, in turn, paid beneficiaries to receive treatment at the medical clinics.  The evidence further established that Pikus and his co-conspirators used sham shell companies and fake invoices to conceal their illegal activities.

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Baker Tilly, Chief Audit Executive, Chief Compliance Officer, Compliance, Corporate Fraud, Corruption, Cross Border Investiga..., Data Analytics, Ethics, Foreign Corrupt Practi..., Forensic Accounting, Fraud, Fraud and Forensic, Fraud and Forensic Inv..., Fraud Investigations, General Counsel, Governance, Internal Audit, Internal Controls, Interview, Investigations, Policies and Procedures, Red Flag, Remote Internal Invest..., Remote Investigations, Risk, Volkov, Webinar, Whistleblower, White Collar Crime Jonathan T. Marks Baker Tilly, Chief Audit Executive, Chief Compliance Officer, Compliance, Corporate Fraud, Corruption, Cross Border Investiga..., Data Analytics, Ethics, Foreign Corrupt Practi..., Forensic Accounting, Fraud, Fraud and Forensic, Fraud and Forensic Inv..., Fraud Investigations, General Counsel, Governance, Internal Audit, Internal Controls, Interview, Investigations, Policies and Procedures, Red Flag, Remote Internal Invest..., Remote Investigations, Risk, Volkov, Webinar, Whistleblower, White Collar Crime Jonathan T. Marks

Webinar - July 28, 2020 - Best Practices for Conducting Remote Internal Investigations

In this pandemic era, global companies have been challenged to maintain a reliable and effective internal investigation program. Companies have relied on remote investigation strategies to collect and review documents and conduct interviews. In conducting remote investigations, companies have to ensure that they follow investigation requirements, maintain the confidentiality of the process, and comply with applicable data privacy rules and security requirements.In this webinar, Jessica Sanderson, Partner at The Volkov Law Group, and Jonathan T. Marks, Partner| Leader of the Global Forensic Investigation, COmpliance & Integrity Practice at Baker Tilly, will discuss best practices for conducting remote internal investigations. They will outline strategies for collecting and reviewing documents, analyzing financial data, and conducting interviews using remote technologies.

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Anti-fraud, Antitrust, Chief Compliance Officer, Compliance, Compliance Coordinator, FCPA, Foreign Corrupt Practi..., Fraud and Forensic Inv..., OFAC, Office of Foreign Asse... Jonathan T. Marks Anti-fraud, Antitrust, Chief Compliance Officer, Compliance, Compliance Coordinator, FCPA, Foreign Corrupt Practi..., Fraud and Forensic Inv..., OFAC, Office of Foreign Asse... Jonathan T. Marks

The Continued Evolution of Best Practices for Compliance Programs

In 2019 and 2020, the federal government released significant information which directly impacted compliance professionals. We cover all three releases in this eBook, the 2020 Evaluation of Corporate Compliance Programs - Guidance Document, the 2019 Framework for OFAC Compliance Commitments, and the 2019 Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations.These three documents provided not only the government’s refreshed thinking on what constitutes a best practices compliance program. I have combined all three onto a best practices document.

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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 Committee, Board of Directors, Books and records, Bribery, Chief Audit Executive, Chief Compliance Officer, Collusion, Compliance Coordinator, Corporate Fraud, Ethics, FCPA, Foreign Corrupt Practi..., Forensic Accounting, Fraud and Forensic Inv..., Fraud Investigations, Fraud Pentagon, Fraud Risk Management, GDPR, General Counsel, Internal Audit, Internal Control Defic..., Internal Controls, Investigations, Jonathan T- Marks, Red Flag, Risk, Risk Assessment, Risk Management, SEC, Skepticism, White Collar Crime Jonathan T. Marks Anti-fraud, Audit Committee, Board of Directors, Books and records, Bribery, Chief Audit Executive, Chief Compliance Officer, Collusion, Compliance Coordinator, Corporate Fraud, Ethics, FCPA, Foreign Corrupt Practi..., Forensic Accounting, Fraud and Forensic Inv..., Fraud Investigations, Fraud Pentagon, Fraud Risk Management, GDPR, General Counsel, Internal Audit, Internal Control Defic..., Internal Controls, Investigations, Jonathan T- Marks, Red Flag, Risk, Risk Assessment, Risk Management, SEC, Skepticism, White Collar Crime Jonathan T. Marks

Bribery Schemes and Their Compliance Responses

This writing will highlight some of the more unusual bribery schemes described in 2019 Foreign Corrupt Practices Act (FCPA) enforcement actions and also consider their impact on compliance programs, what they mean for the compliance professional and how the government could potentially use these cases to require more effective compliance programs going forward.Fraudsters are always looking for loopholes and weak spots to exploit. The same is true for those engaged in bribery and corruption. The role of every compliance professional is to prevent, detect and remediate. By following some of the approaches I have outlined, you can move towards more robust detection.

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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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Compliance, Corporate Fraud, DOJ, Enforcement, Foreign Corrupt Practi..., Fraud and Forensic Inv..., Fraud Investigations, GRC, Investigations, Red Flag, Risk Assessment, Risk Management, Root Cause, SEC, Third Party, Whistleblower, White Collar Crime Jonathan T. Marks Compliance, Corporate Fraud, DOJ, Enforcement, Foreign Corrupt Practi..., Fraud and Forensic Inv..., Fraud Investigations, GRC, Investigations, Red Flag, Risk Assessment, Risk Management, Root Cause, SEC, Third Party, Whistleblower, White Collar Crime Jonathan T. Marks

DOJ Updates FCPA Corporate Enforcement Policy

On November 20th, 2019, The Department of Justice ("DOJ") announced updates to its Foreign Corrupt Practices Act ("FCPA") Corporate Enforcement Policy. While the changes were relatively minor, the modifications underscored important principles surrounding the FCPA Corporate Enforcement Policy.  This latest update follows extensive revisions made in March of this year and the announcement that the FCPA Policy will apply as non-binding guidance for all criminal cases; all reflect DOJ’s continued efforts to promote self-disclosures and provide clarity on DOJ’s approach for companies deciding whether to self-disclose. There is little doubt the DOJ has landed on a Corporate Enforcement Policy that took years to develop. The FCPA Corporate Enforcement Policy now applies to all corporate criminal prosecutions except Antirust Division criminal prosecutions that are guided by the Leniency Program. The DOJ is consistently applying the principles and appears to be very comfortable with the results.

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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, Compliance Coordinator, Crisis Management, Damages, Ethics, Foreign Corrupt Practi..., Fraud and Forensic, Fraud Investigations, Fraud Pentagon, Fraud Risk Management, General Counsel, Governance, IIA, Internal Audit, Internal Controls, Jonathan T- Marks, Management Override, Not for Profit, Regulatory, Remediation, Reputation, Risk, Risk Assessment, Risk Management, Whistleblower, White Collar Crime Jonathan T. Marks Anti-fraud, Audit Committee, Board of Directors, Chief Audit Executive, Chief Compliance Officer, Compliance, Compliance Coordinator, Crisis Management, Damages, Ethics, Foreign Corrupt Practi..., Fraud and Forensic, Fraud Investigations, Fraud Pentagon, Fraud Risk Management, General Counsel, Governance, IIA, Internal Audit, Internal Controls, Jonathan T- Marks, Management Override, Not for Profit, Regulatory, Remediation, Reputation, Risk, Risk Assessment, Risk Management, Whistleblower, White Collar Crime Jonathan T. Marks

Reputation Risk Management Doesn’t Have a Start or End Date!

How can we protect our brand? What are we doing to protect our brand? Questions all board members should be constantly asking.  Reputational risks can damage the most well-crafted business strategies and is a growing challenge that companies around the world are still learning how to manage.By definition, reputational risk refers to the potential for negative publicity, public perception, or uncontrollable events to adversely impact a company's reputation, thereby affecting its revenue.Board directors covet their company’s reputation because it’s their most valuable asset. A study by Deloitte and Forbes affirmed this conviction, but should not surprise anyone.  Senior-level executives also agreed that their company’s reputation presented the greatest risk to the company’s ability to achieve business strategies.

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Audit Committee, Board of Directors, Books and records, Bribery, Chief Audit Executive, Chief Compliance Officer, Collusion, Corporate Fraud, Ethics, FCPA, Foreign Corrupt Practi..., Forensic Accounting, Fraud, Fraud and Forensic, Fraud Investigations, Fraud Risk Management, General Counsel, Governance, IIA, Internal Audit, Internal Control Defic..., Internal Controls, Investigations, Management Override, Red Flag, Sarbanes-Oxley, SEC, White Collar Crime Jonathan T. Marks Audit Committee, Board of Directors, Books and records, Bribery, Chief Audit Executive, Chief Compliance Officer, Collusion, Corporate Fraud, Ethics, FCPA, Foreign Corrupt Practi..., Forensic Accounting, Fraud, Fraud and Forensic, Fraud Investigations, Fraud Risk Management, General Counsel, Governance, IIA, Internal Audit, Internal Control Defic..., Internal Controls, Investigations, Management Override, Red Flag, Sarbanes-Oxley, SEC, White Collar Crime Jonathan T. Marks

FCPA: CEO Overriding/Circumventing and Exploiting Internal Controls, and Issuing False Certifications

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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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Books and records, Bribery, Compliance, Corporate Fraud, Cross Border Investiga..., DOJ, Ethics, Foreign Corrupt Practi..., Fraud and Forensic, Fraud Investigations, Governance, Internal Audit, Internal Control Defic..., Internal Controls, Investigations, Risk, SEC, White Collar Crime Jonathan T. Marks Books and records, Bribery, Compliance, Corporate Fraud, Cross Border Investiga..., DOJ, Ethics, Foreign Corrupt Practi..., Fraud and Forensic, Fraud Investigations, Governance, Internal Audit, Internal Control Defic..., Internal Controls, Investigations, Risk, SEC, White Collar Crime Jonathan T. Marks

Foreign Bribery “Nips” Another for About $300 Million

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