Financial Crime Policies and Procedures: examples of good and poor practice…

The principal catalyst of economic crime (also known as financial crime) is monetary gain. However, economic crime has a devasting effect on individuals and communities. When associated with organised crime and terrorist financing, it threatens laws, democratic processes, and fundamental human freedoms, impoverishing states and distorting free trade and competition. 

Not a victimless crime

Because of the well-publicised financial scandals that marked the aftermath of the tech bubble in 2002 and the housing bubble in 2008, most recently, the 2018 Patisserie Valerie scandal, which was once considered a merely poor business practice (i.e. widespread reckless investment) is now considered criminal. We saw how the vast losses associated with these high-level financial fraud scandals undermined social-security systems and destabilised economic systems. Today there is a growing consensus on the need to improve the global framework for fighting financial crime and regain the public’s trust. And financial crime prevention policies and procedures are critical. 

Walk the walk with a robust code of conduct

The failure of self-regulation by most companies involved in the scandals only highlighted how important organisations have prevention policies and procedures in place. These policies fall under the “Ethical Code of Conduct” A code of conduct sets the standards for how an organisation ought to behave and guides its workforce in the decision-making. A robust Code of Conduct and other internal rules and guidelines serve as the foundation for a successful free of fraud organisation. Read more on “Ethical code of conduct and what should be covered?”

By having a robust code of conduct, organisations can demonstrate their commitment to complying with all applicable laws and regulations. With a well-established set of global policies, the organisation can achieve robust and consistent compliance standards. Rather than assume that ethical rules “go without saying,” every organisation should spell out what they expect of their employees when it comes to ethical behaviour. At CRI® Group, we counsel business leaders that every organisation should have a written, carefully considered ethical code of conduct as part of their fraud prevention strategy. CRI® Group’s Certification program through the ABAC® Center of Excellence includes developing an ethical code of conduct as part of clients’ training and development phase.

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Successful organisations adopt a risk-based approach when doing business…

A company must have up-to-date policies and procedures appropriate to its business. These policies should provide a uniform set of risk management principles and mandatory standards. These should be readily accessible, effective and understood by all relevant workforce.

Self-assessment questions:

  • How often are your organisation’s policies and procedures reviewed, and at what level of seniority?
  • How does it mitigate the financial crime risks it identifies?
  • What steps does the organisation take to ensure that relevant policies and procedures reflect new risks or external events? How quickly are any necessary changes made?
  • What steps does the organisation take to ensure that staff understand its policies and procedures?
  • How do you ensure that policies and procedures are disseminated and applied throughout the business?

Examples of good practice

  • There is clear documentation of the company’s approach to complying with its legal and regulatory requirements concerning financial crime;
  • Policies and procedures are regularly reviewed and updated; and
  • Internal audit or another independent party monitors the effectiveness of policies, procedures, systems and controls.

Examples of poor practice

  • No written policies and procedures;
  • Does not tailor externally produced policies and procedures to suit its business;
  • Takes inadequate steps to communicate policies and procedures to relevant staff;
  • Fails to review policies and procedures in light of events;
  • Fails to check whether policies and practices are applied consistently and effectively; and
  • Has not considered whether its policies and practices are consistent with its obligations under legislation that forbids discrimination.

An Investigative Study Into Causal Factors of the Perpetration of Transnational Financial Crimes

As the global impact of transnational financial crime increases to unprecedented levels, attention has turned to the need to fully understand the motivations that lead to the perpetration of such crimes. CRI® Group has recently published an ebook that provides insightful looks into today’s issues at the forefront of fraud and corruption. They range from deep dives into the U.S., U.K. and other anti-fraud and anti-corruption laws worldwide to close examinations of actual fraud cases that hold lessons for all of us. This ebook provides an in-depth study of transnational financial crimes and the national laws and regulations. Laws in the U.S. and the U.K., in particular, are compared and examined in terms of effectiveness in preventing financial crimes. The comparative study focuses on corporate fraud. “The Catalysts for Economic Crime” pursues the question of how weaknesses in national laws can be considered “a core causal factor in the perpetration of transnational financial crimes.” We invite you to download this ebook and increase your knowledge of fraud, corruption, proper compliance, risk assessments, due diligence, etc.

Download your FREE “The Catalysts for Economic Crime” ebook here!

At CRI® Group, we are always ready to assist you to effectively manage your organisation in an efficient and risk-free manner that best suits your needs. Our experience base, skilled workforce, technical resources, networking capabilities, internal flexibility and global offices maximise our solution efficacy. Explore our broad range of risk management solutions for your business.

CRI® Group’s investigators and Certified Fraud Examiners understand fraud patterns and are trained to recognise the elements of fraud characteristics and where they might come into play at any organisation. Through this knowledge, we can help you uncover the trail of fraud and help bring about a quick and successful resolution.

Having global coverage, CRI® works directly with the key personnel to lead and conduct fraud investigations, including, if needed, your internal board of directors, audit committee, ethics and compliance officers, general and in-house counsel, corporate security, human resources, and C-level executives.

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GDPR vs. UK-GDPR; the laws Post Brexit

The General Data Protection Regulation (GDPR) is a regulation in EU law that was implemented on the 25th of May 2018 and concentrates on data protection and confidentiality in the European Union and the European Economic Area; alongside this, the GDPR is also used to address the transmission of personal data outside the EU and EEA areas. The EU Commission announced on 28 June 2021 that adequacy judgments for the UK have been passed, so what does that mean for the GDPR rules?

The Brexit transition phase concluded on the 31st of December 2020 and as a component of the new trade agreement, the EU has come to an agreement to postpone the transmission limitations for at least four months, which can then be stretched out to six months (recognised as the bridge). The European Commission published its draft decisions on the 19th of February 2021  regarding the UK’s adequacy under the EU’s General Data Protection Regulation (EU GDPR) and Law Enforcement Directive (LED). In both cases, the European Commission has found the UK to be adequate which implies that much of the data can resume the stream from the EU and the EEA devoid of the need for supplementary precautions. Nevertheless, it is vital to take note of the fundamental reality that the adequacy decisions do not cover data conveyed to the UK for the principles of immigration control, or where the UK immigration immunity is appropriate. For this nature of data, distinct regulations are employed, and the EEA dispatcher wants to set other transfer safeguards in place. September 2021 saw WhatsApp being handed the second highest fine under EU GDPR (General Data Protection Regulation) rules and the biggest fine ever from the Irish Data Protection Commission due to their lack of understanding towards the new GDPR laws – had they done their due diligence, they may have been able to avert such a hefty fine. Our Due diligence 360° services provide the specialised intelligence needed by global financial institutions and multinational corporations to guarantee complete compliance with anti-money laundering (AML) regulations and legislations.

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The draft decisions will at this point be deemed by the European Data Protection Board (EDPB) and a committee of the 27 EU Member Governments.  If the committee accepts the draft decisions, then the European Commission can formally adopt them as legal adequacy decisions.  If adequacy decisions are not implemented at the end of the bridge and allocations from the European Economic Area (EEA) to the UK will require compliance with EU GDPR transfer constraints.

What is the UK-GDPR?

The United Kingdom General Data Protection Regulation (UK-GDPR) is the UK’s national data privacy law that is the proxy for the EU’s GDPR after Brexit; it is fundamentally the equivalent to the EU’s GDPR but altered to accommodate national regions of regulation. The UK-GDPR will regulate personal data and demand the same legal grounds for managing personal data.

The GDPR is indeed still retained in domestic law as the UK GDPR, although the UK has the freedom to maintain the framework under evaluation. The ‘UK GDPR’ as it’s known as, rests adjacent to a revised edition of the DPA 2018. It is also essential to note that the fundamental ethics, constitutional rights, and responsibilities remain as they were but that there are connotations for the regulations on transmissions of individual data between the UK and the EEA.

The UK GDPR also pertains to regulators and processors established out of the UK if their managing pursuits correlate to:

  • presenting commodities or services to persons in the UK; or
  • supervising the conduct of persons taking place in the UK.

Similarly, there are also outcomes for UK regulators who have an institution in the EEA, have consumers in the EEA, or observe individuals in the EEA. The EU GDPR still pertains to this handling as data can still flow freely from the EEA because the EU have adopted adequacy decisions about the UK, but the European data protection mandates has altered the way you can interact. CRI® Group’s own exclusive, expert-developed 3PRM™ services help you proactively mitigate risks from third-party affiliations, protecting your organisation from liability, brand damage, and harm to the business. Whether your organisation has a large, well-established third-party program, is in the early stages of development, or is anywhere in between, the 3PRM™ solution can improve the health of your program and future-proof your entire business in many forms.

Find out more about 3PRM™ below or download our free brochure.

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Which rules apply?

Whilst the adequacy judgments stay in order, the UK GDPR is still valid and is expected to remain so until the 27th of June 2025. The EU Commission will be supervising advancements in the UK on a constant basis to guarantee that the UK will continue to deliver a comparable degree of data protection. The Commission is still able to revise, postpone, or rescind the decisions if concerns cannot be settled. EU data subjects or an EU data protection authority can also instigate a lawful dispute regarding the decisions in which the Court of Justice of the European union would then have to determine whether the UK did essentially deliver comparable security.

In the absenteeism of an EU GDPR adequacy decision, the Frozen GDPR would be valid to subjective data of the basis of if:

  • it was administered in the UK under the EU GDPR before 01 January 2021; or
  • it’s being administered in the UK on the basis of the Withdrawal Agreement

Conversely, the UK-GDPR does increase on -and diverge from- the EU GDPR in noteworthy approaches that will make modifications to the legal environment of data protection in the UK.

UK-GDPR expands and changes the European GDPR

The areas increased on by the UK-GDPR are:

  • National security
  • Intelligence services
  • Immigration

These regions, are per definition, are outside the scope of the European GDPR the three of them are deemed to be extra-national regulation from the EU devoid of powers to govern affairs of national confidence in constituent nations. Nevertheless, the UK-GDPR sets out specific concessions by which the customary welfare of personal data can be circumvented, e.g., when in matters of national security or in matters of immigration. It also applies the same requirements for collection and processing of personal data to the intelligence services. A further significant change is that the Information Commissioner, who was the leading data protection authority in the UK today, became the primary director, monitor and enforcer of the UK-GDPR.

Are you post-Brexit GDPR compliant? 

The UK-GDR would now entail your organisation’s site or application to request for the user’s approval prior to accumulating and managing data via cookies. It involves that your organisation not amassing more data than is truly mandatory and to also make it as straightforward for your users to rescind authority to the application of data as it is to give it. Transparency is key in the UK-GDPR and requires clarification of how long data is stored and how you will be processing users’ personal data.

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It’s always great to have a helping hand when it comes to compliance and risk management – especially with all the new changes expected to take place ahead of securing the integrity and morality across corporate culture. Take a proactive stance with the highest level of expertise as a part of your essential corporate strategy. Contact us today to learn more about our full range of services to help your organisation stay protected.

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Why Financial Services Firms Need ISO 37001 ABMS?

When Société Générale, a global financial services institution based in France, agreed to pay a combined total penalty of more than $860 million for an alleged bribery and corruption scheme, it served as a warning shot to financial firms worldwide that a culture of enforcement has arrived. Société Générale was accused of paying bribes to officials in Libya and committing violations in manipulating the London InterBank Offered Rate (LIBOR), one of the world’s leading benchmark interest rates. Together with other regulatory penalties faced by the financial services giant, the total amount to be paid exceeds $1 billion. (The United States Department of Justice, 2018)

Bribery and corruption often go together with money laundering – and, as such, the financial sector faces new Anti-Money Laundering (AML) rules and legislation that is strict and increasingly enforced. Remaining in compliance through implementing proper prevention controls is a must. Failing to do so can mean a loss of business, trust and reputation: Banking giant Citibank was fined $70 million in the US for failing to address shortcomings in its anti-money laundering policies. We at CRI intend on being apart of the solution. Therefore, CRI Group’s ABAC will be hosting a webinar on the 30th of September exploring the Pitfalls Most Organisations Often Commit – the importance of implementing Anti-Bribery Management System (ABMS). Being a part of the solution means sharing our knowledge so society is one step closer to an ethical reality.

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In the US alone, more than 100 bribery investigations were in progress at the end of last year, with the financial services industry facing the most investigations. (Wall Street Journal, 2019)

Having layers of safeguards in place is required both from a legal and compliance standpoint. One of the most critical layers is an effective anti-bribery management system (ABMS).

Prevent corruption and promote compliance

There is a solution that financial services organisations can implement to take a proactive stance against bribery and corruption: The ISO 37001:2016 Anti-Bribery Management System standard. ISO 37001 ABMS is designed to help global organisations implement an anti-bribery management system (ABMS), as the standard specifies a series of measures required by the organisation to prevent, detect and address bribery, and provides guidance relative to that implementation.

For financial services firms, this is a critical layer of protection that provides both anti-bribery controls and a system for compliance with various anti-corruption legislation, such as the FCPA and UK Bribery Act. The UK Bribery Act’s adequate procedures requirement dictates that all companies need to have ongoing monitoring, training, surveillance and risk assessments – ISO 37001 ABMS is designed to fulfil these criteria and more.

CRI Group’s ABAC Certification Services is accredited to offer independent ISO 37001 certification to ensure that an organisation is in compliance with the standard, which is recognised and practised in more than 160 countries worldwide. CRI Group’s auditors and analysts work with financial services organisations to develop measures that integrate with existing management processes and controls, and include:

  • Adopting an anti-bribery policy
  • Establishing buy-in and leadership from management
  • Training personnel in charge of overseeing compliance
  • Communicating the policy and program to all personnel and business associates
  • Providing bribery and corruption risk assessments
  • Conducting due diligence on projects, business associates and other third-party affiliations
  • Implementing financial and commercial controls
  • Developing reporting and investigation procedures

Our paid webinar will have a rundown of the following:

  • What are the core Bribery and Corruption Risks for Financial Institution?
  • How to protect financial institutions and corporations from bribery and corruption risk
  • Reparations from bribery that could affect the businesses, clients, and employees
  • Successful regulations to mitigate risk for bribery and corruption.
  • What can be done if bribery is detected?
  • Internationally recognised solutions laid forth by ISO 37001: Anti-Bribery Management System that gives businesses effective controls to mitigate risk
  • Components of risk management at a financial institution

We will also be exploring how the implementation of such a standard aids in examining and dealing fittingly with any actual or suspected bribery within the corporation and also how to implement appropriate financial, procurement and other commercial controls so as to help prevent the risk of bribery in financial services as these organisations face unique challenges.

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Among them are maintaining proper internal procedures as they relate to bribery and AML regulations. These measures can be logistically challenging, especially in the auditing process – but keeping accurate books and records is a key provision of the UK Bribery Act. ISO 37001 ABMS standard makes this a key provision in cultivating proper due diligence and reporting procedures.

Another major challenge involves monitoring third-party risk. The due diligence practices and risk assessments implemented through ISO 37001 ABMS are critical in this area. Financial services firms, more than any other sector, must conduct effective vetting and ongoing monitoring of third-parties. This goes beyond “on-boarding” and relates to how companies continually assess risk from outside partners – including brokerage firms, introducers, agents, joint-venture relationships, even clients – as borrowers, for example, represent a major risk on the balance sheet.

Some financial services companies do not properly score or assign risk profiles to third-party partners, and this can represent a major weak point in efforts to prevent bribery, corruption and money laundering. Regulators understand this, too. That’s why ISO 37001 ABMS dictates thorough and comprehensive due diligence in regards to all third-parties and especially in the case of mergers and acquisitions.

Once certified, an organisation must continue surveillance and undergo a recertification audit over three years to ensure that the organisation still complies with the ISO 37001:2016 ABMS standard. During this time, any changes to processes, the addition of new partners and expansion/acquisition of new assets or energy contracts, etc. are carefully reviewed.

Long-lasting benefits of certification

ISO 37001 ABMS provides a strong framework for addressing and isolating risk factors, and the benefits of certification are far-reaching, impacting not just the primary organisation but also influencing contractors, clients, and raising the profile of the company as an ethical entity that is a good trading partner. By achieving ISO 37001:2016 ABMS certification, a financial services firm will:

  • Ensure that the organisation is implementing a viable anti-bribery management system utilising widely accepted controls and systems.
  • Assure management, investors, business associates, personnel and other stakeholders that the organisation is actively pursuing internationally recognised and accepted processes to prevent bribery and corruption.
  • If needed, provide acceptable evidence to prosecutors or courts that the organisation has taken reasonable steps to prevent bribery and corruption.

Cases like Société Générale are not isolated, but more and more, we are seeing companies punished for not taking proper preventative action with a robust anti-bribery management system (ABMS). Financial services firms need to be aware and stay in front of increased anti-bribery and corruption legislation given that such regulations have, in most cases, achieved a global reach. For ownership and management, the stakes are especially high – accountability now includes criminal liability for organisation personnel as individuals, beyond (and in addition to) liabilities faced by the organisation. This trend will only continue as governments, and their publics become increasingly intolerant of fraud, bribery and corruption. Significant media coverage and the real and perceived threat to governments’ economies contribute to this changing landscape of public opinion.

As the ISO 37001 International standard document states, “Conformity with (ISO 37001) cannot provide assurance that no bribery has occurred or will occur in relation to the organisation, as it is not possible to eliminate the risk of bribery. However, (the standard) can help the organisation implement reasonable and proportionate measures designed to prevent, detect and respond to bribery”. With this in mind, It’s important to note that ISO 37001 certification, on its own, is not a “safe harbour” from prosecution should bribery or corruption be discovered. Significantly, ISO certification is, as the above explains, a potential mitigating piece of evidence to regulators or even prosecutors and the courts that the entity has taken meaningful steps in its efforts to prevent bribery and corruption.

Financial Services Firms Need ISO 37001 ABMS

It is critical that any financial services organisation have a proper, comprehensive strategy to prevent and detect bribery and corruption, and remain in compliance with all regulations – on the local, regional, and international levels. The ISO 37001 ABMS standard is an established, tried and tested program to address those issues head-on through a comprehensive program of training and certification. The training process is tailored to the organisation while still following the developed curriculum and documented best practices. Due diligence procedures and risk assessments are applied in a thorough, comprehensive manner. Certification requires the demonstration that processes have been implemented effectively, with follow-up evaluations.

Worldwide developments in laws and regulations have demonstrated that there isn’t time to wait to implement controls and compliance procedures – the next investigation and/or prosecution may be too late. The harm caused by bribery and corruption to an entity’s reputation, investments and business can be far-reaching and long-lasting.

This paid webinar will be running from the following times on Thursday the 30th of September;

  • 08:00 to 10:00 GMT
  • 15:00 to 17:00 MYT
  • 12:00 to 14:00 GST

Your turnout with come with a certificate of Attendance (COA) as well as a complimentary webinar ABMS Awareness for 2 Pax per company. While you’re there, why not attain a Continuing Professional Development (CPD) certificate and stay on top of your industry?

Register your place for this webinar here and find out how to tackle the issue of bribery and corruption in your workplace before it has time to manifest itself into a greater issue. Finance is the greatest asset to the economy after all.

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Who is CRI Group?

Based in London, CRI Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business IntelligenceDue Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.

In 2016, CRI Group launched Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.

Top 10 Bribery & Corruption Stories of 2020

Even with much of the world under partial lockdown during the COVID-19 pandemic, there’s been no shortage of bribery and corruption cases through the first half of 2020. Each of these stories makes it clear that organisations must have proper controls in place to prevent bribery and corruption. ISO 37001 Anti-Bribery Management Systems standard provides a comprehensive approach to mitigating bribery and corruption risk.

Organisations of all sizes and industries should take steps now to ensure that they don’t end up on a future list of top bribery and corruption scandals. Due to last year’s “Top 10 Bribery and Corruption Cases of 2019” successful article we decided to compile a 2020 list too. In no particular order, ABAC® Center of Excellence collated the top bribery and corruption stories we’ve seen so far in 2020.

In no particular order, here are 10 of the top bribery and corruption stories we’ve seen so far in 2020.

#10. Airbus

In February, French-based Airbus agreed to pay a record $4 billion in fines for alleged bribery and corruption spanning at least 15 years. The company reached a plea bargain with prosecutors in Britain, France and the United States. According to prosecution documents, Airbus used a global network of agents or middlemen for corrupt transactions, included payouts disguised as commissions to push airplane sales.

“Fallout from the Airbus bribery scandal reverberated around the world on Monday as the head of one of its top buyers temporarily stood down and investigations were launched in countries aggrieved at being dragged into the increasingly political row.” (Reuters, 2020)

#9. Novartis

While the investigation into suspected corruption at Novartis began seven years ago, it appears that 2020 is the year the company can finally close this damaging chapter in its history. The resolution comes at a steep cost. The Swiss-based pharmaceutical company will pay a staggering $1.3 billion in a settlement for kickbacks, bribery and price-fixing.

“The latest settlements cover two different cases. In the first, federal prosecutors claim Novartis used ‘tens of thousands of’ speaker programs and events — some entailing exorbitant meals — as disguise to provide bribes to doctors. The goal, according to prosecutors, was to encourage doctors to prescribe its drugs, including Lotrel, Valturna, Starlix, Tekturna, Tekamlo, Diovan and Exforge.” (Fierce Pharma, 2020)

#8. Ohio House Speaker Larry Householder

While political corruption is nothing new, his constituents were nevertheless shocked when Ohio House Speaker Larry Householder was arrested, along with four alleged co-conspirators, as part of a $60 million racketeering and bribery investigation. The alleged scheme is being described as one of the biggest public corruption cases in Ohio, U.S. history.

“All the charges are tied to what federal prosecutors said was a criminal enterprise dedicated to securing a bailout for two nuclear power plants in northern Ohio owned by FirstEnergy Solutions of Akron. The bailout is expected to cost the state’s utility ratepayers $1 billion.” (Cincinnati Enquirer, 2020)

#7. Alexion Pharmaceuticals

Charged by the SEC with violating the FCPA by bribing officials in Turkey and Russia, Alexion Pharmaceuticals will pay $21.4 million to resolve an investigation that began in 2015. The Connecticut, U.S.- based company was also accused of failing to keep accurate financial records at subsidiaries in Brazil and Colombia.

“In Turkey and Russia, Alexion paid government officials and doctors at state-connected hospitals to promote use of its blood-disease drug, Soliris. Alexion retained a consultant in Turkey from 2010 to 2015 with ties to health officials. Alexion Turkey paid the consultant over $1.3 million for ‘consulting fees and purported expense reimbursements,’ the SEC said. … In Russia, Alexion paid doctors at government hospitals over $1 million from 2011 to 2015 to increase Soliris prescriptions. … The bribery resulted in Alexion being ‘unjustly enriched’ by about $6.6 million in Turkey and $7.5 million in Russia, the SEC said.” (FCPA Blog, 2020)

#6. Taiwan Presidential Office Secretary-General Su Jia-chyuan

In Taiwan, a scandal embroiling some top legislators prompted Presidential Office Secretary-General Su Jia-chyuan to resign from office. Su Jia-chyuan’s nephew, Democratic Progressive Party (DPP) Legislator Su Chen-ching, is reportedly under investigation in a bribery case related to the ownership of a department store. Su Jia-chyuan said he has “nothing to hide” and insisted he is stepping down to avoid letting the controversy continue to affect the president.

“Taipei prosecutors on Saturday filed a motion to detain Su Chen-ching, along with four other former and incumbent lawmakers as part of an investigation into bribery allegations against six current and former legislators and their aides. The court hearing on whether to grant the prosecutors’ request to detain them was ongoing as of press time last night. The DPP’s anti-corruption committee convened a meeting at 8 pm to discuss the penalties for Su Chen-ching and former legislator Mark Chen, who has also been implicated in the case and was released on NT$500,000 bail early on Saturday.” (Taipei Times, 2020)

#5. Former Malaysia Prime Minister Najib Razak

As part of the 1MDB corruption scandal, former Malaysian Prime Minister Najib Razak was convicted on seven counts for charges that include money laundering, abuse of power and criminal breach of trust. Investigators said he transferred about $10 million from a 1MDB affiliate to his own bank accounts, and the Malaysian High Court agreed. Razak was forced out of office in 2018 during the scandal.

“In 2015, the Wall Street Journal reported that Najib deposited about $700 million from 1MDB into his personal accounts. He has always denied the allegations. He faces more trials in Malaysia on at least 35 additional corruption charges. The judge Tuesday imposed a 12-year prison sentence on Najib, 67, but suspended it during any appeals.” (FCPA Blog, 2020)

#4. Alstom

A multi-year, multi-million-dollar bribery and money laundering investigation involving Alstom Indonesia resulted in more indictments this year. Reza Moenaf, former president, and Eko Sulianto, former director of sales, for Alstom Indonesia were charged along with a former deputy general manager of Marubeni Corporation’s overseas power project department. They are accused by the U.S. Justice Department of violating the Foreign Corrupt Practices Act (FCPA) and of conspiracy to commit money laundering.

“According to the Justice Department, Kusunoki, Moenaf, and Sulianto engaged in a conspiracy to pay bribes to officials in Indonesia — including a high-ranking member of the Indonesian Parliament and the president of Perusahaan Listrik Negara, the state-owned and state-controlled electricity company in Indonesia — in exchange for assistance in securing a $118 million contract, known as the Tarahan Project, for Alstom Power and its consortium partner, Marubeni, to provide power-related services for Indonesian citizens.” (Compliance Week, 2020)

#3. Los Angeles City Councilman Jose Huizar

Corruption in local politics is still a major issue, especially in a major city like Los Angeles, U.S.  That’s where City Councilman Jose Huizar is alleged to have engaged in a wide array of bribery and corruption acts to enrich himself and his associates. He now faces a laundry list of charges after a federal grand jury returned a 34-count indictment against Huizar.

“Huizar was charged last month with one count of conspiracy to violate the Racketeer Influenced and Corrupt Organizations (RICO) Act. Thursday’s indictment charges Huizar with the following criminal charges: 12 counts of honest services wire fraud; two counts of honest services mail fraud; four counts of traveling interstate in aid of racketeering; six counts of bribery; five counts of money laundering; one count of structuring cash deposits to conceal bribes; one count of making a false statement to a financial institution; one count of making false statements to federal law enforcement; and one count of tax evasion, according to prosecutors.” (CBS News, 2020)

#2. Asante Berko, Former Goldman Sachs Executive

Former Goldman Sachs executive Asante Berko was charged by the SEC as a result of their investigation into his alleged bribery plot. Berko is accused of FCPA violations in his effort to help an energy company based in Turkey secure a contract for a power plant in Ghana. He was charged in a civil complaint in New York, U.S., for “aiding and abetting violations of the FCPA anti-bribery provisions.”

“According to the SEC, Berko helped the Turkish energy company pay at least $2.5 million to a Ghana-based intermediary, ‘all or most of which was used to bribe Ghanaian government officials’ to secure approval of an electrical power plant project. … In 2015, Berko negotiated a contract for the Turkish energy company to pay the intermediary $2.5 million at first, and up to $42 million over five years, the complaint said.” (FCPA Blog, 2020)

#1. Cardinal Health

Ohio, U.S.-based Cardinal Health paid the SEC $8.8 million Friday to settle FCPA offenses related to a Chinese subsidiary that provided marketing services. Cardinal Health allegedly violated provisions for maintaining books and records, as well as internal accounting controls. Cardinal Health first began doing business in China after acquiring an existing company and rebranding it. It appears the company made voluntary disclosures and has been taking proactive steps to address the corruption issues in its ranks.

“In 2016, Cardinal China learned that the marketing employees and the dermocosmetic company had disguised some ‘marketing payments’ that were funneled to healthcare professionals who provided marketing services, as well as other employees of state-owned retail entities. The state-owned entities had influence over purchasing decisions related to the dermocosmetic company’s products. Cardinal took steps to stop the suspect payments in 2016 when it learned about the misconduct, the SEC said. In December 2016, Cardinal voluntarily disclosed the results of its internal investigation to the SEC.” (FCPA Blog, 2020)

Stay tuned for Part 2 or follow us on LinkedInFacebook or Twitter for more industry news and insights.

Staying one step ahead of any critical risk to your organisation is part of being an effective business leader. Contact us today to get started on implementing a robust program that will serve you well for years to come. Get your FREE QUOTE now!

We Welcome You To Have Free Gap Analysis of Highest Ethical Business Survey: prove that your business is ethical. Complete our FREE Highest Ethical Business Assessment (HEBA) and evaluate your current Corporate Compliance Program.

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Find out if your organisation’s compliance program is in the line with worldwide Compliance, Business Ethics, Anti-Bribery and Anti-Corruption Frameworks. Let ABAC® experts prepare a complimentary gap analysis of your compliance program to evaluate if it meets “adequate procedures” requirements under UK Bribery Act, DOJ’s Evaluation of Corporate Compliance Programs Guidance and Malaysian Anti-Corruption Commission.

The HEBA survey is designed to evaluate your compliance with the adequate procedures to prevent bribery and corruption across the organisation. This survey is monitored and evaluated by qualified ABAC® professionals with Business Ethics, Legal and Compliance background. The questions are open-ended to encourage a qualitative analysis of your Compliance Program and to facilitate the gap analysis process.

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Based in London, CRI® Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk ManagementEmployee Background ScreeningBusiness IntelligenceDue DiligenceCompliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are, we have the network needed to provide you with all you need, wherever you happen to be. CRI® Group also holds BS102000:2013 and BS7858:2019 Certifications is an HRO certified provider and partner with Oracle.

In 2016, CRI® Group launched the Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management SystemsISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI® Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.

MEET THE CEO

Zafar I. Anjum is Group Chief Executive Officer of CRI® Group (www.crigroup.com), a global supplier of investigative, forensic accounting, business due to diligence and employee background screening services for some of the world’s leading business organisations. Headquartered in London (with a significant presence throughout the region) and licensed by the Dubai International Financial Centre-DIFC, the Qatar Financial Center – QFC, and the Abu Dhabi Global Market-ADGM, CRI® Group safeguard businesses by establishing the legal compliance, financial viability, and integrity levels of outside partners, suppliers and customers seeking to affiliate with your business. CRI® Group maintains offices in UAE, Pakistan, Qatar, Singapore, Malaysia, Brazil, China, the USA, and the United Kingdom.

Contact CRI® Group to learn more about its 3PRM-Certified™ third-party risk management strategy program and discover an effective and proactive approach to mitigating the risks associated with corruption, bribery, financial crimes and other dangerous risks posed by third-party partnerships.

CONTACT INFORMATION

Zafar Anjum, MSc, MS, CFE, CII, MICA, Int. Dip. (Fin. Crime) | CRI® Group Chief Executive Officer

37th Floor, 1 Canada Square, Canary Wharf, London, E14 5AA United Kingdom

t: +44 207 8681415 | m: +44 7588 454959 | e: zanjum@crigroup.com

The Role of a Fraud Investigator

Fraud investigators are the front line of establishing the facts of suspected fraud or other unethical business behavior. A fraud investigator’s skillset and wide knowledge of fraud laws, evidence gathering and interviewing make them the go-to expert for investigating insurance fraud, financial fraud, procurement fraud, asset recovery, cyber fraud, healthcare fraud, retail fraud and other areas.

A fraud investigator can either be part of a team of experienced investigators, or the leader of such a team. If part of a team, the fraud investigator generally works with the other team members to handle reports of suspicious activity. If in charge of a team, the fraud investigator would typically report to the head of a department, such as corporate security, compliance or audit. A fraud investigations manager at a typical retail business, for example, would be responsible for the day-to-day monitoring, investigation and resolution of fraudulent activity relating to delays in the repayment and refunds processes. They will take the lead on the implementation of strategies to prevent fraud and financial crime, thereby mitigating risk to the business.

Fraud Investigator Key Functions

Fraud investigators provide subject matter expertise on claims and associated fraud risks, helping to ensure effective resolution of investigations. The effective fraud investigator adheres to relevant security standards, internal and external procedures and legislative requirements. Their role often involves developing and maintaining close working relationships with relevant law enforcement agencies, ensuring that cases are developed and prosecuted to a criminal standard.

When working with an organization in a preventative fashion, a fraud investigator will perform fraud risk assessments across the business relating to both external and internal threats; implementing mitigation measures as required. They also build appropriate fraud prevention and detection processes and implement them. Some fraud investigators manage the day-to-day operation of an expanding fraud team, ensuring that KPIs are met and regular reports produced for the management team. In this capacity, they will also work closely with the senior management team to ensure that operational capacity is correctly aligned to combat a variety of fraud types.

Here are some of the other key functions performed by fraud investigators:

  • Evaluate potential fraud indicators and the impact of current fraud trends and make recommendations as to appropriate mitigation.
  • Conducting investigations into allegations of fraud, waste or abuse committed by clients against our company
  • Reviewing and researching evidence/documents to analyze the overall fact pattern of a claim and synthesize data into a professional report with recommendations
  • Preparing and coordinating field assignments to obtain relevant evidence and information
  • Conduct objective, fair, thorough, unbiased and timely investigations into allegations of fraud, waste or abuse committed by clients against our company
  • Review and research evidence/documents to analyze the overall fact pattern of a claim and synthesize data into a professional report with recommendations
  • Prepare and coordinate field assignments to obtain relevant evidence and information
  • Coordinate with defense attorneys to provide deposition strategies and use law enforcement resources for assistance
  • Manage and priorities a large and varied caseload effectively and efficiently to achieve positive results
  • Prepare prosecution packages and restitution proposals.

Responsibilities

As a fraud investigator often wears many different hats, they also have many ongoing responsibilities. These include monitoring transaction reports to identify any suspicious transactions and conducting detailed investigations as required. They must also proactively identify financial crime trends through data analysis and share findings with leadership as and when needed. A few other responsibilities of a fraud investigator include:

  • Working to a high standard, meeting strict time-frames whilst working under pressure.
  • Communicating directly with customers as part of ongoing fraud investigations through in-app messages or via telephony with potential victims of fraud to establish circumstances and additional information, before providing a fair and logical decision, with supporting rationale.
  • Work as part of a team and supporting colleagues as and when required to reduce workload(s).

Personality Traits of a Fraud Investigator

There are some common traits among the most successful fraud investigators. This includes being a self-starter who is results-driven with high levels of self-motivation, energy and initiative. An effective fraud investigator has a proven ability to work under pressure to and meet tight deadlines, without compromising the quality of output. One key trait that can’t be overlooked is the ability to be an effective communicator – a fraud investigator must have excellent written and verbal skills. Here are some other key traits among successful fraud investigators:

  • An ability to thrive under pressure amidst changing business priorities
  • Effective cost management and analytical integrity
  • Experience in leading and developing a team
  • Keen interest in stopping fraud whilst considering the impact of how an investigation can impact customers

Knowledge and Skills

A successful fraud investigator brings to the table a broad range of security/ fraud detection and prevention experience. A fraud investigator must be a subject matter expert on fraud for their related field, such as insurance fraud, financial fraud, procurement fraud, asset recovery, cyber fraud, healthcare fraud, retail fraud and other areas.

Many fraud investigators have specialized skills such as:

  • Experience of interviewing in accordance with the Police and Criminal Evidence Act following the PACE framework.
  • Strong knowledge of cyber risk and common fraud typologies, along with the emerging trends affecting fraud and financial crime.
  • Familiarity with key AML, TF, Financial Crime and Sanctions legislation and associated Regulatory Guidance.
  • Demonstrated experience working with customers on fraud prevention and detection strategies.
  • Sound understanding of the customer impact of a transaction monitoring system; able to balance fraud prevention with the need to provide an excellent customer experience.

As previously mentioned, an effective fraud investigator must have strong interpersonal and communication skills, including the ability to interact with clients, upper management and law enforcement. They also need to have an ingenuity and persistence to obtain case information not readily available with an eye for detail. Dealing with various different cases and different types of evidence requires strong organizational skills. For insurance fraud, investigators must be proficient with the insurance procedures, regulations and investigation methods

Perhaps most important, fraud investigators must set a positive example for their colleagues. They need to be honest and ethical, with high levels of integrity and confidentiality.

A fraud investigator has many different responsibilities, and the role requires an individual with some specific traits. CRI Group’s fraud investigators are experts at uncovering the facts and evidence of a case, but they also implement proactive anti-fraud measures to help an organisation be better protected against future incidence of fraud. Fraud investigators specialise in insurance fraud, financial fraud, procurement fraud, asset recovery, cyber fraud, healthcare fraud, retail fraud and other areas. It’s important that organisations hire trained, qualified fraud investigators who understand the laws, are effective at evidence collection and fact-finding, and are good communicators (since interviewing is one of the key processes of fraud investigation). A fraud investigator might work with a team, or they might lead their team and report to another division. Being able to work under pressure and meet deadlines is critically important. Properly evaluating and securing evidence is of equal importance. CRI Group has only the best expert fraud investigators to meet these challenges.

Are you a fraud investigator? Tell us about your day-to-day job, we would love to hear it.

 

Who is CRI Group?

Based in London, CRI Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business IntelligenceDue Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.

In 2016, CRI Group launched Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organizations. Contact ABAC® for more on ISO Certification and training.

 

 

 

FTC guide for small business to avoid Scams

Federal Trade Commission (FTC) has released a guide for small business.
Scams & Your Small Business guide is part of FTC’s efforts to help small business owners to avoid scams.

If you are a small business owner or are part of a non-profit organisation, you spend a time and energy on making sure your organisation works well. But when scammers go after your business, it can hurt your reputation and your bottom line. The guide explains common scams that target small businesses, describes scammers’ tactics, and provides steps that you can take to protect your business from scams. Tell your employees and colleagues what to look for so they can avoid scams.

Scams & Your Small Business guide can be your best protection against scammers. Check out the guide here!

Speak up against scams

Report any illegal, unethical, or improper behaviour. Our Ethics and Compliance Hotline is an anonymous reporting mechanism that facilitates reporting of possible illegal, unethical, or improper conduct when the normal channels of communication have proven ineffective, or are impractical under the circumstances.

At CRI® Group, we are committed to having an open dialogue on ethical dilemmas regardless. This hotline is available to all employees, as well as clients, contractors, vendors and others in a business relationship with CRI® Group and ABAC® Group.

Compliance Hotline is accessible by both phone and online. If you make a report directly by telephone, you will speak with the Compliance Department directly. If you submit a report online, the system will guide you through the reporting process, and a PIN number will be generated automatically once you complete the report.

About us…

Based in London, CRI® Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk ManagementEmployee Background ScreeningBusiness IntelligenceDue DiligenceCompliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are, we have the network needed to provide you with all you need, wherever you happen to be. CRI® Group also holds BS102000:2013 and BS7858:2019 Certifications is an HRO certified provider and partner with Oracle.

In 2016, CRI® Group launched the Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management SystemsISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI® Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.

MEET THE CEO

Zafar I. Anjum is Group Chief Executive Officer of CRI® Group (www.crigroup.com), a global supplier of investigative, forensic accounting, business due to diligence and employee background screening services for some of the world’s leading business organisations. Headquartered in London (with a significant presence throughout the region) and licensed by the Dubai International Financial Centre-DIFC, the Qatar Financial Center – QFC, and the Abu Dhabi Global Market-ADGM, CRI® Group safeguard businesses by establishing the legal compliance, financial viability, and integrity levels of outside partners, suppliers and customers seeking to affiliate with your business. CRI® Group maintains offices in UAE, Pakistan, Qatar, Singapore, Malaysia, Brazil, China, the USA, and the United Kingdom.

Contact CRI® Group to learn more about its 3PRM-Certified™ third-party risk management strategy program and discover an effective and proactive approach to mitigating the risks associated with corruption, bribery, financial crimes and other dangerous risks posed by third-party partnerships.

CONTACT INFORMATION

Zafar Anjum, MSc, MS, CFE, CII, MICA, Int. Dip. (Fin. Crime) | CRI® Group Chief Executive Officer

37th Floor, 1 Canada Square, Canary Wharf, London, E14 5AA United Kingdom

t: +44 207 8681415 | m: +44 7588 454959 | e: zanjum@crigroup.com

Banking industry squad prevents £20m of fraud

Banking industry squad disrupted 23 Organized Criminal Groups (OCGs) preventing £20 million of fraud. The specialist police unit (DCPCU) is funded by the finance and banking industry in a dedicated effort to stop fraud.

Commonly known as the banking industry squad, the DCPCU (Dedicated Card and Payment Crime Unit) is a joint effort between the Metropolitan Police Service, the City of London Police as well as banking industry fraud investigators. Supported by UK Finance, DCPCU is on the frontline in the fight against fraud. And over the past year, the unit has worked in partnership with several social media platforms to take down over 1,600 accounts which featured posts relating to payment:

  • 500 “money mules” accounts used to recruit young people
  • 250 accounts involved in the trading stolen card details
  • +400 “brokers” accounts 
  • with the rest of the accounts used for “flipping”

In 2019 DCPCU seized £1.65 million of assets – over double the amount confiscated in the same period in 2018 – with a total of 75 fraudsters convicted to a total of 100 years in prison. DCPCU operational successes include:

The DCPCU is very effective in disrupting criminals and a powerful example of how important is it that all sectors – i.e. banking industry – work with law enforcement to protect the public from fraud. 

Read more on what the Head of the DCPCU, Detective Chief Inspector Gary Robinson, UK Finance Managing Director of Economic Crime and National fraud coordinator, Commander Karen Baxter have to say. Read NOW!

About us…

Based in London, CRI® Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk ManagementEmployee Background ScreeningBusiness IntelligenceDue DiligenceCompliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are, we have the network needed to provide you with all you need, wherever you happen to be. CRI® Group also holds BS102000:2013 and BS7858:2019 Certifications is an HRO certified provider and partner with Oracle.

In 2016, CRI® Group launched the Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management SystemsISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI® Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organizations. Contact ABAC® for more on ISO Certification and training.

 

MEET THE CEO

Zafar I. Anjum is Group Chief Executive Officer of CRI® Group (www.crigroup.com), a global supplier of investigative, forensic accounting, business due to diligence and employee background screening services for some of the world’s leading business organisations. Headquartered in London (with a significant presence throughout the region) and licensed by the Dubai International Financial Centre-DIFC, the Qatar Financial Center – QFC, and the Abu Dhabi Global Market-ADGM, CRI® Group safeguard businesses by establishing the legal compliance, financial viability, and integrity levels of outside partners, suppliers and customers seeking to affiliate with your business. CRI® Group maintains offices in UAE, Pakistan, Qatar, Singapore, Malaysia, Brazil, China, the USA, and the United Kingdom.

Contact CRI® Group to learn more about its 3PRM-Certified™ third-party risk management strategy program and discover an effective and proactive approach to mitigating the risks associated with corruption, bribery, financial crimes and other dangerous risks posed by third-party partnerships.

CONTACT INFORMATION

Zafar Anjum, MSc, MS, CFE, CII, MICA, Int. Dip. (Fin. Crime) | CRI® Group Chief Executive Officer

37th Floor, 1 Canada Square, Canary Wharf, London, E14 5AA United Kingdom

t: +44 207 8681415 | m: +44 7588 454959 | e: zanjum@crigroup.com

7 Traits of a Resilient Leader

Every successful leader has encountered a challenging scenario at some point in their career. The unprecedented COVID-19 pandemic, however, has forced leaders to face unforeseen new challenges. With the pandemic’s colossal impact on operations, workforces, profits and supply chains across the globe, all eyes are on leadership to guide their businesses through this crisis. Resilient Leader

Resilient leaders are generally seen as more effective, making them an asset to any business; but what is resilience and how can it be applied to your management skills?

What is Resilience?

Resilience is the capacity to recover quickly from difficulties; it is a further evolution of stress management. This makes it a “no brainer” as to why resilience is such a popular concept in today’s business environment. Many businesses are pushing the concept of resilience as a way of helping workers better cope with the stresses and strains of the modern-day office and unlock their performance potential.

In this article, we look at seven essential qualities that characterise resilient leaders, and how to increase your resilience. In general, resilient leaders:

  1. Show empathy
  2. Are adaptable and able to improvise
  3. Are self-aware and open to feedback
  4. Take calculated risks
  5. Keep a positive attitude
  6. Develop others
  7. Communicate effectively

1. Resilient Leaders Show Empathy

COVID-19 has generated one of the greatest challenges and, simultaneously, one of the greatest opportunities for resilient leaders – at all levels. According to a Gallup U.S poll, six in 10 people are “very” or “somewhat worried” that they or a family member will be exposed to COVID-19 (Gallup, 2020). During this crisis, emotional management is even more crucial than ever. According to studies carried out by Development Dimensions International (DDI), empathy is the most critical leadership skill. Leaders who display compassion, authenticity and vulnerability – and are capable of apologising when they’re wrong and handle criticism without blame – create strong emotional bonds with their teams (DDI, 2020).

The most resilient (and effective) leaders can demonstrate empathy and a high level of emotional intelligence. When your team feels understood, they feel more motivated and more confident to contribute cultivating stronger conversations, ideas and debate. As Mark Cuban shared in a recent interview: “How you treat your employees today will have more impact on your brand in future years than any amount of advertising, any amount of anything you literally could do” (Just Capital, 2020).

2. Resilient Leaders Are Adaptable

With COVID-19 infecting approximately 311,641 people in the UK alone, health officials suggested using hand sanitiser as the easiest way to prevent the spread of the disease. Consequently, these announcements led to panic buying (Euronews, 2020). In this type of situation, a resilient leader should be able to visualise this action as an opportunity – for example, dozens of spirit manufacturers across the UK started to produce hand sanitisers (i.e. BrewDog and Leith Gin). This is a classic example of an instant attitude adjustment – looking at what they can do as opposed to what they can’t (Telegraph, 2020).

When faced with change, resilient leaders can focus on the things within their business that they can still control. Whether impacted by new technologies, environmental challenges or even ethical dilemmas, the modern business landscape is always changing. A resilient leader needs to be flexible and adaptable to succeed. Is flexibility part of your leadership style?

3. Resilient Leaders Are Self-Aware and Coachable

According to Health Care Business Today, self-awareness and coachability are “The Two Most Important Leadership Traits” (Health Care Business Today, 2019). We think so, too. Resilient leaders are self-aware, confident, and most of all, able to recognise their strengths and overcome their weaknesses. Resilient leaders are open to feedback, ask for feedback and are always demonstrating a real effort to improve.

4. Resilient Leaders Take Calculated Risks

Successful leaders earned their success through taking calculated risks. When Amazon CEO Jeff Bezos launched AmazonFresh, he was scrutinised by others because he didn’t choose a successful delivery or supermarket executive to run the venture. Instead, Bezos selected a team that had previously run a web-based food delivery service in the ‘90s (which collapsed after two years in business). Why? Bezos knew that the team had learned from their failure, which made them the perfect choice to succeed with a new project.

Resilient leaders like Bezos take calculated risks while accepting that failure is a by-product of innovation and success. They learn to become comfortable with being uncomfortable, and flourish as the world changes around them.

5. Resilient Leaders Can Keep a Positive Mindset

The impact of COVID-19 is tough to manage. It is vital to have a positive mindset that can influence fellow professionals and raise team morale while maintaining business momentum.

Under the challenging circumstances posed by the COVID-19 crisis, a resilient leader needs to be enthusiastic, offer praise for success, and give credit when it’s due. American psychologist Carol Dweck has stated in her book “Mindset: The New Psychology of Success” that “a change of mindset must happen before other positive transformation can occur.”

Resiliency is needed when we encounter failure. As a resilient leader, you shouldn’t view failure as final, but as a necessary step to move further along your journey.

6. Resilient Leaders Develop Others

The most resilient leaders are concerned about the development of their teams. Developing others helps everyone to learn from their mistakes. We continue to find that leaders who want and accept honest feedback for themselves are more likely to give productive feedback and coaching to others.

7. Resilient Leaders Communicate Effectively

Effective communication helps teams understand changes, expectations and new directions. This understanding is the key to the success of any team. The most resilient and best leaders always communicate their intentions effectively to others and are willing to help their teams understand a new strategy or direction.

The COVID-19 pandemic is proving to be the ultimate test for business leadership. In times of crisis, only certain individuals can adapt and stand tall amongst the crowd. When it comes to leaders, being able to implement resilience tools and strategies will not only make you a better leader but help the company overall.

 

Who is CRI Group?

Based in London, CRI Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business IntelligenceDue Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.

In 2016, CRI Group launched Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.

Fraud Advisory Panel deep dives into the HBOS scandal

On 30 January 2017, following a four-month trial, former HBOS employees Scourfield and Mark Dobson involved in HBOS scandal were convicted of fraud and corruption involving a scheme that cost the bank £245m. Scourfield pleaded guilty to six counts including corruption, and Dobson was found guilty of counts including bribery, fraud and money laundering.

The HBOS (Halifax Bank of Scotland) fraud trial was highly unusual in that senior bankers were convicted of crimes, including fraud and hiding the proceeds of crime, in the boom of irresponsible lending ahead of the 2008 crash. As Lloyds reopens compensation claims over HBOS fraud and almost a decade after the HBOS fraud victims will hopefully be finally compensated. Loyds damning review found that victims were not all treated equally after fraudsters plundered £1bn to fund sex parties, superyachts and lavish holidays. The victims were the taxpayer, small business customers of the bank, and HBOS shareholders.

Fraud Advisory Panel

Fraud Advisory Panel discusses the HBOS scandal in an executive breakfast briefing. Which will take a deep dive into the case and take stock of the significant challenges faced by counter-fraud professionals to ensure fair access to justice for those affected by fraud and financial crime, especially SMEs. The agenda is comprised of the following:

  • The impact of the HBOS fraud on its victims.
  • The practical challenges faced by law enforcement and prosecutors in large corporate frauds.
  • The work of the APPG on Fair Business Banking to support SME victims.
  • The key lessons that can be learnt from HBOS and how these can be used to inform proactive action to support victims.

Guest speakers

  • Nick Gould, Aria Grace Law
  • Brian O’Neill QC, 2 Hare Court
  • Anthony Stansfeld, Police Crime Commissioner, Thames Valley
  • Kevin Hollinrake MP Thirsk and Malton, Co-chair,  All Party Parliamentary Group on Fair Business Banking

In the chair

  • Rachel Sexton, director, Fraud Advisory Panel

Details

Date: 5 August 2020
Time: 08:30 – 10:30
Location: Online
Venue: Live interactive session
Costs: FAP member £20+VAT; Non-member £30+VAT

Register HERE!

Staying one step ahead of any critical risk to your organisation is part of being an effective business leader. Contact us today to get started on implementing a robust program that will serve you well for years to come. Get your FREE QUOTE now! 

About us…

Based in London, CRI® Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk ManagementEmployee Background ScreeningBusiness IntelligenceDue DiligenceCompliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are, we have the network needed to provide you with all you need, wherever you happen to be. CRI® Group also holds BS102000:2013 and BS7858:2019 Certifications is an HRO certified provider and partner with Oracle.

In 2016, CRI® Group launched the Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management SystemsISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI® Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.

MEET THE CEO

Zafar I. Anjum is Group Chief Executive Officer of CRI® Group (www.crigroup.com), a global supplier of investigative, forensic accounting, business due to diligence and employee background screening services for some of the world’s leading business organisations. Headquartered in London (with a significant presence throughout the region) and licensed by the Dubai International Financial Centre-DIFC, the Qatar Financial Center – QFC, and the Abu Dhabi Global Market-ADGM, CRI® Group safeguard businesses by establishing the legal compliance, financial viability, and integrity levels of outside partners, suppliers and customers seeking to affiliate with your business. CRI® Group maintains offices in UAE, Pakistan, Qatar, Singapore, Malaysia, Brazil, China, the USA, and the United Kingdom.

Contact CRI® Group to learn more about its 3PRM-Certified™ third-party risk management strategy program and discover an effective and proactive approach to mitigating the risks associated with corruption, bribery, financial crimes and other dangerous risks posed by third-party partnerships.

CONTACT INFORMATION

Zafar Anjum, MSc, MS, CFE, CII, MICA, Int. Dip. (Fin. Crime) | CRI® Group Chief Executive Officer

37th Floor, 1 Canada Square, Canary Wharf, London, E14 5AA United Kingdom

t: +44 207 8681415 | m: +44 7588 454959 | e: zanjum@crigroup.com

Ethical code of conduct: What should be covered?

Business leaders are usually quick to communicate their expectations to employees, especially when it comes to financial goals or tasks that they want to be accomplished. However, what is often lacking is a clear, concise explanation of what the organisation expects in terms of ethical behaviour. The recent article “Puffery or Not? Courts Examine Corporate Codes of Conduct” explains that although a number of federal courts have found code of conduct statements to be non-actionable puffery, given the uncertainty in the face of the novel CODIV19 pandemic, public companies are ought to review their codes of conduct and revise them if necessary to mitigate litigation risk. Ethical code of conduct:

Does your organisation have an ethical code of conduct? If not, you might be making assumptions that your employees know to conduct themselves in an ethical manner, when, in fact, this expectation only exists in a grey area in their minds – if at all. In fact, some employees who have engaged in fraud, corruption or other unethical situations have claimed that while they knew their behaviour was wrong, they thought it was implicitly accepted by their bosses and, in some cases, their company overall.

Rather than assume that ethical rules “go without saying,” every organisation should spell out what they expect of their employees when it comes to ethical behaviour. At CRI Group, we counsel business leaders on the principle that every organisation should have a written, carefully considered ethical code of conduct as part of their fraud prevention strategy. CRI’s Certification program through the ABAC Center of Excellence includes developing an ethical code of conduct as part of the training and development phase for clients.

What should be covered?

An ethical code of conduct should be tailored to your company and your organisation – no two will be the same. What are the risks inherent in your organisation? What about in your industry? A pharmaceutical company will have some different risk areas than a retail store, for example. A nonprofit organisation might have concerns that relate to fundraising, a government agency might be focused on preventing bribery or collusion.

The goal of an ethical code of conduct is to help all employees understand the expectation that they always behave in a legal and ethical manner, and that the organisation has zero tolerance for unethical behaviour. It should include the following focal points:

1. Business values

This can include your organisation’s mission and vision and should help set the tone for how the organisation relates to its clients, partners, its own employees and the public at large.

2. Guiding principles

The principles that guide your company include customer satisfaction, financial success and profitability, improvement and growth. Your company might also follow policies of corporate responsibility, such as respect for social and environmental issues, and support of the community and/or nonprofit efforts.

3. Role of leadership

This section of the code of conduct should state that management has clearly endorsed the code and that employees can approach any manager or executive with ethical concerns or complaints.

4. Regulatory and compliance

This section should communicate the organisation’s commitment to meeting all compliance requirements, from OSHA and EPA to Sarbanes-Oxley and Dodd-Frank. This reinforces leadership’s expectation that employees must act diligently and ethically to uphold those standards, as well.

5. Employee responsibility

Every employee, from top to bottom, shares the responsibility toward upholding the ethical standard defined in the code. Contractors and volunteers are also expected to follow the standard of behaviour.  Furthermore, the code should make clear that if the unethical behaviour is detected, turning a blind eye or deciding “it’s not my problem” is unacceptable. That is a breach of the ethical code.

CRI Group can help your organisation with the finer points of drafting and implementing an ethical code of conduct. ABAC Center of Excellence includes this critical piece as a part of any robust fraud, bribery and corruption prevention program.

After the ethical code of conduct is approved by company leadership, it should be read and signed by all employees (with the signed copies kept on file by the organisation). And it should be displayed prominently in the office. Unethical behaviour, including fraud and other corruption, is everyone’s problem, and it must be prevented, detected and reduced. Staying one step ahead of any critical risk to your organisation is part of being an effective business leader.

ISO 37001:2016 Anti-Bribery Management System certification is offered under CRI Group’s ABAC® Centre of Excellence, an independent certification body established for Anti-Bribery Management System training and certification, ISO 37301 Compliance Management Systems and Risk Management System certification. The program will be tailored to your organisation’s needs and requirements. For assistance in developing and implementing a fraud prevention strategy, contact ABAC today or get a FREE QUOTE now!

 

Who is CRI® Group?

Based in London, CRI® Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk ManagementEmployee Background ScreeningBusiness IntelligenceDue Diligence and other professional Investigative Research solutions provider. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI® Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.

In 2016, CRI® Group launched the Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management SystemsISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI® Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.