To Check or Not to Check?

Background Checks: To Check or Not to Check?

Background checks don’t tend to make international news. They are the low-key diligent step in most well-managed recruitment processes to comfort employers that the person they are hiring is everything they seem – and nothing more.

That’s why the background checks of Belle Gibson, a super influencer who lied about having cancer, and Brett Kavanaugh, a nominee to the US Supreme Court, tend to make news headlines for who can you trust if not those in direct line of the public eye?

The Story of Belle Gibson & Brett Kavanaugh

Belle Gibson was a Melbourne “wellness” who rose to fame after sharing her story on Instagram of her terminal brain cancer and how she controls it through the power of healthy eating. Gibson claimed to have kept her cancer under control by turning away conventional medicinal practices and instead of following what she termed a “wellness” diet, a diet consisting of avocados, berries, no alcohol and so on.

Sounds impressive, right? To rid yourself of an incurable disease simply through eating better? Think again – it is too good to be true. The influencers lie caused untold damage, including turning a 44-year-old mother away from her chemotherapy in hopes of attaining Ms Gibson’s lifestyle.

But the reason why this lie broke headlines is because of what followed; a book deal with Penguin Books publishing company and an Apple app titled ‘The Whole Pantry’. It was evident that neither the tech giants nor the publishers thought to verify her assertions, thus leading to a $320,000 fine and a lot more emotional damage for the individual’s that Ms Gibson had provided false hope.

Context is everything, of course, and this job-for-life is one of the more crucial public office positions in the United States. Mr Kavanaugh had undergone six separate background checks during his career before the latest, which the FBI recently completed on behalf of the White House. Each of these will have been meticulous and thorough, right down to interviews with neighbours and acquaintances.

But you don’t have to be entrusted with national security clearance to pose a real risk to your employer. All staff members are in a position of trust, and even the humblest labourers or office workers will have privileged access to property – whether physical or intellectual. And this is not a theoretical risk – it’s a truism that employees or contractors cause the vast majority of security breaches.

The Compliance Perspective

Interviewing the ex-wives and sports coaches of factory and desk clerks is overkill and not economic. And that is where professional background checking comes in. It allows low hassle, cost-effective and fast checking for all recruits and employees to ensure everyone is what they claim to be, from the CEO to the company mascot.

Such checks will cover everything required to give HR directors and governing boards peace of mind: from criminal record checks and right-to-work documentation to education and qualification verifications and employment records.

A properly systematised process, supported by local intelligence, is essential to keeping costs low without compromising quality or effectiveness.

CRI Group™ is one of the few providers with a truly global reach and more than thirty years of experience in the sector. Our proven process means that we have one of the fastest turnaround times in the industry – typically just 3-5 days. Meanwhile, our more than 175 investigatory experts on the ground across the US, Europe, the Middle East and Asia, ensure we can navigate local customs, processes and regulations, no matter where your employees are based.

About 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 Intelligence, Due 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 B.S. 102000:2013 and B.S. 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 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 international 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.

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How to Identify and Prevent Employee Fraud?

In 2017 the major European ABB conglomerate admitted that an employee took advantage of serious management failings to disappear with $103 million of the firm’s cash. According to CNN business, ABB CEO Ulrich Spiesshofer and Chief Financial Officer Eric Elzvik admitted that the organizations managers had failed to maintain sufficient segregation of duties in the treasury unit of its subsidiary in South Korea and did not provide enough oversight of local treasury activities.

To top it all off, ABB also failed to keep the signature seals of the South Korean unit secure which as a result, has lead the company became “bound to unauthorized financial contracts, resulting in undetected financial obligations.” 

Organizations rely on the honesty and integrity of their employees, however employee fraud does unfortunately cost companies vast sums of money. Employee fraud is a reality across all sectors – no matter how credible a job applicant is and how stringent your hiring process is – your business is at risk.

Tips on Identifying and Preventing Employee Fraud

When you trust your employees, it is difficult to think the worst of them, even when there are red flags – circumstances or patterns that are out of the ordinary – alerting you to the contrary. If you have suspicions of employee fraud, it is recommended to hire a forensic accountant to help you detect fraud, understand your circumstances, and put together evidence to target and confront the employee without tipping them off.

The good news is that you can plan and train your team to prevent this from taking place; the best thing you can do for your business is to learn how to recognise the warning signs of employee fraud and have robust procedures in place to minimise the risks and opportunities for fraud. Employee fraud covers a wide range of fraudulent activities in the workplace and can vary in seriousness including embezzlement.

Embezzlement involves an employee who transfers company funds into their bank account. One example of an act of embezzlement is deliberately writing cheques in the employees’ name or diverting company assets without authorisation, e.g. customers unknowingly pay into an employee-controlled bank account, not the business’. This is serious fraudulent behaviour, but employees usually get away with it without raising any suspicion by creating non-existent suppliers and fake employees or using counterfeit credit notes to hide/disguise misappropriated monies.

An easy way to spot this type of financial fraud is to scour through the bank statements and financial records of your organisation and check for irregular activities or patterns of unusual and unauthorised transactions.

Another common sign of embezzlement is when either an employee or a manager/director begins to enjoy a lavish lifestyle that is obviously beyond their means, e.g. holidays, cars, clothes/jewellery. In the case that you suspect an employee or director might be embezzling funds from within your company, it is essential to be discreet in your employee fraud investigation to prevent the employee from covering their tracks and disposing of substantial evidence.

Other Common Types of Employee Fraud

• Commission fraud – inflating sales figures to gain a more significant commission than deserved.
• Petty fraud – for example, embellishing an expense claim or taking office supplies.
• Money laundering – hiding the origin of illegally obtained money and washing it through your business.
• Insider Trading – making a profit by using valuable information that is unavailable to the public to their advantage, for example, confidential information that could impact the prices of shares, securities, goods/commodities.
• Manipulation of accounts – false information on sales, purchases or stock can be used to perpetrate fraud for personal financial gain, e.g. overstated trading profits to receive cash/share bonuses, or get a promotion, creating false trading accounts or stock/fixed asset write-offs to obtain goods.

What Can You Do (as an employer) to Minimize Employee Fraud?

The most effective way to minimize employee fraud as an employer is to implement robust management procedures and employee background screening; the implementation of these preventative measures will ensure staff are adequately investigated and monitored and consider the possibilities for collusion between employees – including a conflict of interest. Paying attention to only the procedures within your accounts department is not sufficient. The same procedures can help you across your operations, including sales and procurement.

Minimize the chances of employee fraud with the following procedures:

• Separation of employee responsibilities such as placing orders, recording invoices and collecting debts.
• Requiring purchase or payment authorization by more than one person.
• Compare actual to budgeted expenditure for unexpected patterns.
• Examine bank reconciliations thoroughly.
• Scrutinize cancelled cheques and cheques made out to employees or unusual vendors.
• Review supplier invoices for significant amounts, pricing or volumes.
• Verify credit notes and write-offs with receiving records.
• Install and monitor CCTV to deter theft of stock or equipment.

Fraud Triangle

An American criminologist, Donald R Cressey, devised a theory that involved three aspects that trigger fraud. Understanding these triggers will help you prevent fraud:

• Opportunity – the lack of internal controls or reporting structure/oversight increase the chance of fraud.
• Rationalization – the fraudster will rationalize the continued deception, which increases slowly, perhaps over a few years, becoming an entitlement, i.e. I deserve this. This offers the chance to stop some employee fraud early if robust detection procedures are in place.
• Pressure – overwhelming pressure, be it business factors such as company targets to meet or personal pressures, such as gambling or financial problems.

Implement Pre-employment and Post-employment Employee Screening Now!

Preventing financial loss is crucial for your business’s survival and expansion, which is why it’s essential to know and understand its obvious signs. Use the list above as a guide to protecting your organization.

To detect employee fraud professionally and thoroughly, it is recommended you seek the expertise of a skilled employee fraud accountant as early as possible. They can help you investigate your employees by reviewing your bank statements and financial documents and advise you whether an employee is committing fraud and to what extent. A forensic accountant’s report will also give you the evidence you need to take the necessary action against your employee and act as a deterrent to others.

For a Free and Confidential Chat to Discuss How We Can Help Your Business, contact us. 

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Risks of Cybercrime and Social Media: NEW PLAYBOOK

The risks of cybercrime claims many victims over many sectors. The PwC Global Economic Crime Survey 2020 found that a company falls victim to six frauds on average. The most common types are customer fraud, asset misappropriation as well as cybercrime. It also proved a roughly even split between frauds committed by internal and external perpetrators, at almost 40% each – with the rest being mostly collusion between the two. Few can deny the enormous technological advancements that are constantly taking place in the modern world. The internet, the computer, and other technological advancements have dramatically changed what it means to socialise, ‘chat’, and even read a book. Both the disadvantages and advantages of such developments are clear, and as technology gains pace, so have the unlawful activities of those who seek to take advantages of such developments.

According to a 2020 cybercrime report from Europol, COVID-19 sparked upward trend in cybercrime. In fact, since the beginning of the pandemic, the FBI has seen a fourfold increase in cybersecurity complaints, whereas the global losses from cybercrime exceeded $1 trillion in 2020. 

In other words, as technology evolves, the risks of cybercrime have become complex. The sense that one is safe from crime in the privacy of one’s own home has been lost. In fact, according to World Economic Forum’s “Global Risks Report 2020” the chances of catching and prosecuting a cybercriminal are almost nil (0.05%).

Take the First Steps Towards Developing Measures Against the Risks of Cybercrime! 

This playbook critically examines the growth of cybercrime, evaluating the risks it poses in terms of the different forms of cybercrime that exist and the regulations that seek to detect, prevent and punish them.

The extension of an old legislation to include cybercrime is not entirely effective – especially not for crimes committed within the realm of social media and social networking. Therefore the need to develop an ‘anti-cybercrime culture emerges. It has to be implemented on an international scale that safeguards these crimes – the promotion of careful use would therefore be facilitated to hinder such crimes before they can materialise. Our playbook includes:

• What is cybercrime and why is it important?
• Top corporate cybersecurity risks and 10 types of high-tech crimes
• How cybercrime impacts business and your company’s growth
• Cybercrime and regulations in place
• And how your response as a business matters – how to can you protect your business from cybercrime including advice and tips on how to telework safely

Download the full playbook today and learn step-by-step things your company can do to be better protected from cybercrime. Robust cyber-security, data protection, anti-fraud and risk management all come together to mitigate the dangers posed by hackers, phishers and other cybercriminals.

DOWNLOAD PLAYBOOK

With the playbook in your hands, you’ll learn about the most common cyber attacks. This includes viruses, phishing attacks and website hacks. You’ll also gain a better understanding of the consequences of different types of cybercrime.

To sum it up, the playbook provides best-practices and ways that companies are lessening their risk without spending prohibitive resources to do so. Above all, the right expert advice means that any company can be on the right track to protecting their customers, their assets, and their employees from the risks of cybercrime.

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 Intelligence, Due 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 B.S. 102000:2013 and B.S. 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 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.

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New European Parliament Corporate Due Diligence and Corporate Accountability

Corporate due diligence and corporate accountability, ending an era of voluntary policing. A new EU mandate places liability on companies unable to assess and mitigate unethical third-party behaviour. New legislation requires companies operating in the EU to ‘identify, address and remedy their impact on human rights and the environment throughout their global value chains.’

Situation Analysis:

• In 2017, nearly 25 million people categorised as victims of forced labour. International Labour Organization, 2017 report
• From 2000-2012, nearly 25% of all tropical deforestation was due to illegal agro-conversion for export markets. 2019 study

Global economies have significantly benefited from an increase in cross-border and international business partnerships, which has led to a substantial expansion of the global value chain. Subsequently, more and more companies are being exposed to potential liability by unscrupulous third-party providers in their supply chain pipeline with little respect for business ethics, human rights or the environment.

There is a growing concern worldwide of the many supply chain businesses linked to severe abuses, including exploitative working conditions, modern slavery and child labour, toxic pollution, rampant destruction of rainforests and a general disregard for corporate governance.

For decades, companies have voluntarily monitored supply chain partners for bad behaviour, but this self-policing has limited. But now, the European Union Parliament has presented mandates for EU businesses – under penalties of law – to carry out due diligence to identify, prevent, mitigate and account for actual or potential human rights violations and negative environmental impacts in their operations and supply chain. 

“We live in a world where businesses with the wherewithal can still shift their adverse social and environmental impact to the most vulnerable people and places on the planet.” Lara Ianthe Wolters, Member, European Parliament

The Challenge: You are Liable for the Conduct of Your Partners; Lack of Due Diligence will Get you into Trouble

The legislation requires companies operating in the EU to identify, address and remedy their impact on human rights (including social, trade union and labour rights), the environment (contributing to climate change or deforestation) and good governance (such as corruption and bribery) throughout their value chain.

This is akin to saying that if a company fails to conduct due diligence on a third-party partner that engages in slave labour, pollutes the environment, manipulates the price or violates jurisdictional regulations, that company is essentially complicit in the partnering company’s illegal behaviour. It may be held liable in a court of law.

Aside from legal and monetary penalties, the company further risks a tarnished reputation in the market and a devaluation of its brand.

It’s crucial for businesses utilising global supply chain partners to conduct due diligence and assess the potential risks that a third party may pose to your organisation, particularly when addressing risks associated with environmental damage and human rights violations.

The Solution: Identify Unethical Behaviour and Protect Your Organisation with 3PRM, Corporate Due Diligence and Risk Management

CRI Group™ developed a highly specialised assessment solution for Corporate Due Diligence and Third-Party Risk Management to assist organisations in accurately identifying, preventing, mitigating and addressing actual and potential adverse impacts of affiliating with global partners and complies with all EU mandates.

From enhanced due diligence to identify non-compliance of the regulatory framework and damaging environmental allegations to investigating company (or stakeholder) human rights violations related to labour laws, child labour or human trafficking, CRI Group experts help determine the legal compliance, financial viability, and integrity levels of outside partners and suppliers affiliated with your company’s value chain.

Outcomes

Recent studies have demonstrated a positive correlation between the extent to which companies implement environmental, social and good governance policies, and their overall economic performance, all while contributing to a more stable global marketplace. Such responsible business conduct:

• Enhances protection for workers
• Improves access to justice for victims
• Safeguards the environment
• Ensures fair products for consumers

Further, apart from general compliance with EU mandates, such organisations enjoy a wealth of intangible benefits, including:

• Reduced overall liability risks
• Improved stakeholder protection
• Lower costs resulting from conflicts
• Improved company transparency
• More profound knowledge of the value chain
• Enhanced reputation in the market 
• Improved social standards for workers

“The global pandemic has demonstrated that resilient global supply chains that protect both the people and planet will be crucial to companies and economic recovery in the future.” Transparency International EU

CRI Group’s corporate due diligence and accountability solutions can help your organisation comply with a growing list of global regulations and mandates related to human rights and the environment while acting as an integral part of your business decision-making and risk management systems. 

Are you prepared to conduct a due diligence assessment on your global partners? Contact CRI Group to learn more about our Corporate Due Diligence and Accountability solutions and stay one step ahead of the pending EU mandates. We look forward to assisting you.

Zafar I. Anjum | MSc, MS, LLM CFE, CIS, MICA, Int. Dip. (Fin. Crime), Int. Dip. (GRC), MBCI, CII Int. Dip. (AML)

Group Chief Executive Officer, Corporate Research and Investigations Limited

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

Our enhanced Integrity Due Diligence services will ensure that working with an, i.e. potential trade partner will ultimately achieve your organisation’s strategic and financial goals. To find out more about each level of due diligence, contact CRI Group HERE!

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John Wood Group to Pay $177 Million to Settle Bribery Charges Inherited Through its Merger

John Wood Group Bribery Probe Trace Back to its Merger with Amec Foster Wheeler Plc.

The Importance of Due Diligence in Merger and Acquisition to Avoid a Similar Incident Happened like in John Wood Group.

Due diligence is understood as the reasonable steps taken to satisfy legal requirements in the conduct of business relations. That allows you to reduce risks – including risks arising from the FCPA (Foreign Corrupt Practices Act) and the UKBA (UK Bribery Act), to make informed decisions and to pursue takeovers or mergers with more confidence.

Unlike other kinds of control (audits, market analysis, etc.), it must be completely independent and rely as little on information provided by the researched subject. The other important difference lies in the methodology: commercial or financial due diligence analyses available information, investigative type provides reliable and pertinent, but raw, information.

Due diligence on potential business partners when adding a new vendor or hiring a new employee is vital to confirm the legitimacy and reduce the risks associated with such professional relationships. Global integrity due diligence investigations provides your business with the critical information it needs to make sound decisions regarding mergers and acquisitions, strategic partnerships, and the selection of vendors, suppliers, and employees.

It will ensure that working with an, i.e. potential trade partner will ultimately achieve your organisation’s strategic and financial goals. CRI Group investigators employ a proven, multi-faceted research approach that involves a global array of databases, courts and public record searches, local contacts, industry and media resources, and in-depth web-based research. Our resources include:

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Tackling Corporate Fraud in the Middle East

Tackling corporate fraud in the middle east has become even more challenging during the pandemic. ICAEW Insights sat down with our founder and chief executive, Zafar Anjum, to discuss the rising levels of corporate fraud in the middle east during the pandemic.

Find out how CR™ is using AI to investigate wrongdoing; from fake degrees and doctored CVs to false insurance claims and bogus bills, our corporate fraud investigators in the Middle East have seen it all. Zafar told ICAEW his firm was busier than ever as the pandemic triggered a rise in white-collar crime cases across the region.

From its base in London, CRI™ has been helping firms in middle east regions like Qatar, Dubai, Abu Dhabi and Saudi Arabia. Regions where anti-fraud frameworks are still being built out inside the embryonic corporate regulatory regimes that govern the Middle East.

“We’ve seen a lot of insurance fraud claim investigations, fake bills, fake debts and fraudulent certificates designed to cheat insurance companies,” Zafar said. “Covid allowed internal controls to be relaxed; people are working from home, so the usual check and balances are missing.”

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The Story of Our CEO and Company

The Story of CRI Group™

By Zafar I. Anjum, Group CEO

THE BEGINNING: EVENT THAT CHANGED ME

Shortly after leaving the Pakistani Rangers in 1994 (five years after my graduation), I took over my father’s private investigation organisation – called, at the time, the Metropolitan Detective Agency. During this period, I was involved in investigating a case of suspected insurance fraud. The case involved a grandfather attempting to lay claim to his daughter’s life insurance settlement following her death under the pretext that he was responsible for the guardianship of her four orphaned children. After investigation, it was revealed that this was not the case and that the grandfather was attempting to defraud his late daughter’s insurance company.

Much like my feeling towards the case, the situation’s outcome could be characterised in two ways – one positive and one negative. I remember the overwhelming pride I felt in our success on the positive side. However, this was somewhat overshadowed by a sense of what is perhaps best articulated as injustice – I saw first-hand how fraud is damaging. And although fraud was having (and continues to have) a detrimental effect on the people, the lack of an effective solution to the problem meant that, frustratingly, such crimes were able to continue.

UNCOVERED MY FIRST FRAUD; WHAT’S NEXT?

Whilst I had managed to deal with one case of fraud and thus prevented the successful committing of a crime, this was just a single instance of fraud – I had done nothing to move towards an overall reduction of the problem. In other words, I concluded that I had managed to treat a mere symptom rather than the underlying illness.

DEDICATION TO INVESTIGATING FRAUD

Although the case itself was not particularly unusual, at least as far as fraud cases go, one particular aspect of the affair struck me – that, in contrast, most crimes are dealt with by the justice system, and fraud is peculiar. It often mandates investigation by an external agency or organisation that specialises in fraud detection. I noticed that such organisations were sorely lacking in Pakistan at the time – and that there was a distinct lack of counter fraud education in the general population, which aided those committing fraud greatly. Furthermore, even where individuals were aware that they were being defrauded, they lacked knowledge of effectively resolving disputes between themselves and the defrauder.

With this analysis in mind, I concluded that there needed to be significant growth in the counter-fraud industry within Pakistan. This is where the privatised nature of fraud investigation could make a significant positive impact. 

Although the police might not have had the resources to deal with fraud in its entirety, there was certainly an incentive for private companies to increase their spending in this area. In other words, there was a clear market opportunity for the expansion of the anti-fraud industry, and one that I knew how to fill with my experience and knowledge. Although I am market-minded as a matter of business necessity, it has become apparent to me over recent years that I am at my most motivated not when I am seeking organisational growth but when I am seeking professional development.

Corporate Research and Investigations Ltd (CRI Group’s First Logo)

FUTURE PLANS: CRI GROUP™ EXPANSION

With this conclusion in mind, I continued with the operation and expansion of Corporate Research and Investigations Limited “CRI® Group”. As well as expanding the CRI® Group, I began to take more and more of an interest in the professional aspects of fraud investigation. For this reason, in 1995, I became the first member of the Association of Certified Fraud Examiners from Pakistan, and in 1998 I was appointed the Area Governor for Pakistan and the Middle East by the World Association of Detectives.

The Area Governor appointment letter, issued to Zafar Anjum by
World Association of Detectives, 1998

If I were to summarise the one lesson that I learned due to my early experiences in Pakistan, it would be important to expand counter-fraud and counter-corruption to where it is needed. The ramifications of this lesson did not end when I left Pakistan either. My awareness of areas into which fraud prevention might be further expanded has continued. For this reason, I have taken a particular interest in the emerging area of corporate corruption and fraud.

CRITICAL REFLECTIONS ON MY PERSONAL DEVELOPMENT

Being a business owner, it is only natural that my personal development has been attached to the development of my organisation. As noted above, I have sought to have my organisation grow in line with my field – where there has been a need to combat corporate corruption and fraud, I have sought to conquer the resulting market. Similarly to how I have sought to expand my business, I have also found it necessary to seek out personal development opportunities whenever they become available. To this end, I have consistently been seeking out academic development since 2009. I have since completed an ICA International Diploma in Financial Crime Prevention, ICA International Diploma Governance, Risk and Compliance, ICA International Diploma in Anti-Money laundering, and MSc in Counter Fraud and Counter Corruption Studies. I completed another Master in Fraud and Financial Crime with Distinction and a Master of Laws (Legal Practice Intellectual Property). It is only natural that I am currently seeking to learn academically and contribute something to academia in the form of my PhD thesis.

In terms of personal development, I can therefore consider myself lucky to bring my career experience to doctorate-level study. Still, I will be able to take what I have learned at the doctorate level and apply it in a professional setting. Although I am market-minded as a matter of business necessity, it has become apparent to me over recent years that I am at my most motivated not when I am seeking organisational growth but when I am seeking professional development.

Hard work and dedication are two values ingrained into our core and are found in all facets of our operation. We believe that true value comes from fostering trust with our colleagues and clients at an equal level. We take great care in keeping integrity at the forefront of our Anti-Corruption, Compliance and Risk Management services. We wish to build long-term relationships in which we can be counted on to provide efficient and cost-effective services.

CRI Group’s very first international directory advertising in the UK during 1998

Looking Forward…

I believe it is important to constantly look for ways of improvement, especially in this rapidly changing industry. Each new technological development is an opportunity for us to advance our capabilities and competencies. Making use of the finest equipment and the most advanced technologies is one of the many ways that we set ourselves apart from the competition. I take great pleasure in implementing the most innovative ways to provide for our colleagues and team.

Our goal is to provide principled and reliable Anti-Corruption, Compliance and Risk Management Services for our clients. With the shifting marketplace, we pride ourselves on maintaining our core values as a constant. The message to our client is that your satisfaction is the main driving force behind our business. When you choose our services, you can expect a professional, high-quality experience every time.

Thank you all for your dedication, and congratulations on our 32nd anniversary!

With gratitude and wishing for more years to come for the CRI Group™ family,

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What’s Law vs Allowed with Pre-employment Screening Around the World:

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Q&A on How Corporate Fraud and Corruption Affect Businesses in the UAE 2021

CRI Group™ and its ABAC™ Center of Excellence were featured in Financier Worldwide’s InDepth Feature: Corporate fraud and corruption 2021. In this edition, CRI Group’s CEO Zafar Anjum and ABAC Group’s Scheme Manager Huma Khalid talk about how corporate fraud and corruption affect businesses not only in the UK and UAE, but across the globe, and provide solutions and insights for businesses to become better protected from corporate fraud, bribery and corruption.

Q. To What Extent have you seen a Notable Rise in the Level of Corporate Fraud, Bribery and Corruption Uncovered in the UAE?

A. The United Arab Emirates (UAE) remains the least corrupt country in the Middle East and North Africa region. It was perhaps fitting that the United Nations (UN) held its anti-corruption conference in the UAE just over a year ago. At the conference, delegates drafted anti-corruption resolutions and discussed asset recovery, international cooperation, and other topics in preparation for an upcoming special session of the UN General Assembly against corruption. Of course, there is still much work to be done. Fraud, bribery and money laundering are still problems in the UAE that require a united focus to overcome. Of special concern is the real estate sector, which some have called a haven for stashing and laundering cash. In some cases, these funds are linked to terrorist financing, raising the alarm beyond just the balance sheet for typical financial or corporate fraud.

Q. Have there been any Legal and Regulatory Changes Implemented in the UAE Designed to Combat Fraud and Corruption? What Penalties do Companies Face for Failure to Comply?

A. The recent Anti-Commercial Fraud Law in the UAE strengthened rules around counterfeiting and intellectual property (IP) theft, among other areas. In addition, lawmakers and regulators are applying an anti-fraud focus to other laws. A perfect example is the UAE’s Insolvency Law 2020. The Ministry of Finance announced that penalties will be imposed on those who fraudulently abuse the law. This could include making a fake claim or a sham debt against a debtor or illegally increasing a debt amount. Such offences are punishable by jail time and fines. An awareness campaign by the UAE Banks Federation (UBF), the Central Bank of the UAE (CBUAE), Abu Dhabi Police, and Dubai Police was the first such collaboration in the UAE and it comes as both corporate and consumer fraud have increased. Companies are expected to protect their stakeholders’ investments, and failure to do so can lead to regulatory and legal punishments.

Q. In your Opinion, do Regulators in the UAE have Sufficient Resources to Enforce the law in this area? Are they Making Inroads?

A. There are at least two daunting tasks facing regulators in the UAE at present: detecting and preventing money laundering and stemming the growing threat of cyber crime. While these problems are not unique to the UAE, they do require significant investment and increased investigation and enforcement efforts. Recent reports allege that illicit funds flow through ‘free trade zones’ and into real estate deals, such as luxurious properties in Dubai and other locations. The laws are in place to punish such crimes, but more inroads will need to be made to bring this under control in a country that largely succeeds at fighting fraud in other areas. Cyber crime is also a constant challenge that has been exacerbated by the COVID-19 pandemic. Many fraudsters have sought to take advantage of companies having to transition to different employment models, such as remote working. Fraud fighters are working hard to stay ahead of the curve in this regard.

Q. If a Company Finds itself Subject to a Government Investigation or Dawn Raid, How Should it Respond?

A. If a company finds itself under investigation, one of the first things it must do is mandate down the chain of command that employees cooperate fully with investigators. Any efforts to the contrary may be considered obstruction, and lead to more punishments or a higher likelihood of penalties at the end. In contrast, engaging in a good-faith effort to assist an investigation may weigh in the company’s favour.

Questions will arise, such as: Was this a surprise? What are the facts of the case? How did this occur? Legal counsel must be engaged immediately, but it is also important to speak with compliance officers, risk management, executives and the board in a transparent way to help the company move forward. Communicate a zero-tolerance policy toward fraud, and if employees are proven to have engaged in such behaviour, they should be terminated and prosecuted.

Q. What Role are Whistleblowers Playing in the Fight Against Corporate Fraud and Corruption? How Important is it to Train Staff to Identify and Report Potentially Fraudulent Activity?

A. Some business leaders falsely believe that audits, account reconciliation and other procedures offer the best protection against fraud. They are important functions, but they are not the most effective detection method. Fraud is often uncovered by tips, according to the ACFE’s Report to the Nations on Occupational Fraud and Abuse. Employees are truly the front line of defence for companies, and the first to throw up warning flags about unethical behaviour. The question is whether companies listen to their employees. And is there an easy, anonymous way for employees to submit tips, without fear of retaliation? Companies should educate employees about the red flags of fraud, and then make sure they know they can and should report it.

Q. What Advice can you Offer to Companies on Conducting an Internal Investigation to Follow up on Suspicions of Fraud or Corruption?

A. If the company does not have an experienced team of anti-fraud professionals on staff, it is crucial to enlist the help of an outside firm with experts who specialise in this area. There are mistakes companies make at the beginning of an investigation that can haunt them later. For example, most countries, including the UAE, have laws that govern the proper collecting and handling of evidence. With most evidence in a digital format, following the right protocols is more important than ever. There are also important guidelines for interviewing witnesses and those suspected of fraud which, when disregarded, could lead to a failed investigation. The bottom line is: do not go it alone – get expert professional help. And if criminal conduct is discovered, contact the authorities.

Q. What General Steps can Companies take to Proactively Prevent Corruption and Fraud within their Organisation?

A. Preventing and detecting fraud starts with a company’s employees, so training and communication are key. First, employees must be trained on what constitutes fraud, bribery and corruption, how to recognise it, and how to report it. Second, the company must communicate that fraud will not be tolerated on any level, and those who commit fraud will be terminated and prosecuted if they are found to have broken the law. Companies should also have anti-corruption and anti-fraud controls in place, including an employee code of conduct, regular and surprise audits, and a fraud reporting system available to employees, contractors and even customers. Achieving certification in internationally recognised standards, such as ISO 37001 ABMS, is a good practice too. When it comes to fraud and corruption, an ounce of prevention is worth a pound of cure. Being proactive is truly the only practical option for protecting the business and its assets.

Meet HUMA KHALID,  Scheme Manager

Huma Khalid, as scheme manager, is responsible for leading ABAC. Ms Khalid’s responsibilities include planning and overseeing all aspects of the ABAC programme, which include certification and training. Additionally, she oversees the compliance department for the implementation, management and internal audit of CRI Group’s and ABAC compliance programmes

ABAC™ Center of Excellence Limited | t: +44 (0)777 652 4355 | e: huma.k@abacgroup.com

About CRI Group™

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 intelligence, due diligence, compliance solutions and other professional investigative research solutions provider. CRI Group™ has the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Its global presence ensures that no matter how international your operations are, the company has the network needed to provide you with all you need, wherever you happen to be. For more on our Risk Management solutions just check out our brochure:

View Risk Management Solutions Brochure

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Corporate Fraud and Corruption: Affect on UK Businesses in the 2021

CRI Group™ and its ABAC Center of Excellence were featured in Financier Worldwide’s InDepth Feature: Corporate fraud and corruption 2021. In this edition, CRI Group’s CEO Zafar Anjum and ABAC’s Scheme Manager Huma Khalid talk about how corporate fraud and corruption affect businesses not only in the UK and UAE, but across the globe, and provide solutions and insights for businesses to become better protected from corporate fraud, bribery and corruption.

Q. To what extent have you seen a notable rise in the level of corporate fraud, bribery and corruption uncovered in the UK?

A. The COVID-19 pandemic has created increased opportunities for fraud worldwide. The UK is not immune, unfortunately, and such a disruptive event as the pandemic increases the likelihood that normal safeguards and risk management controls can be bypassed and subverted. There has been an increase in reported fraud and corruption cases over the past year. A survey of fraud experts by the Association of Certified Fraud Examiners (ACFE) in August 2020 showed that 77 percent were seeing an increase in fraud. Perhaps not surprisingly, cyber fraud is the fastest-growing problem area, but there has also been an uptick in unemployment fraud. This is bad news in the UK, where fraud is our most common crime, costing the country £190bn annually, according to the Royal United Services Institute (RUSI).

Q. Have there been any legal and regulatory changes implemented in the UK designed to combat fraud and corruption? What penalties do companies face for failure to comply?

A. There is proposed legislation, supported by the secretary of state of the UK’s Department of Business, Energy and Industrial Strategy, that would increase accountability for corporations that produce falsified financial statements. This includes a provision that would require company directors to personally sign off on their corporation’s financial statements, under penalty of fines and possible prison time. Under the Sarbanes-Oxley Act in the US, the penalty for falsely certifying such statements is steep: up to 20 years in prison and up to $5m in fines, and the UK is looking at similar measures to step up its fight against fraud and corruption. The UK also recently approved the formation of an audit, reporting and governance authority (ARGA) that should come into force within the next two or three years. Accordingly, the UK is taking a stronger stance against fraud going forward.

Q. In your opinion, do regulators in the UK have sufficient resources to enforce the law in this area? Are they making inroads?

A. Combatting fraud is never straightforward. When looking at progress in detecting and preventing fraud, it sometimes feels like a question of whether the glass is half full or half empty. For example, the Serious Fraud Office (SFO) brought 13 fraud defendants to trial in 2019 and 2020, with a 95 percent fouryear success rate by case. Many of these represent large frauds, and they are meaningful wins, but how many more fraudsters are out there undiscovered? Other bodies, including Her Majesty’s Revenue and Customs (HMRC), among others, also have key roles to play in investigating fraud, but a considerable amount of fraud is still investigated and prosecuted at the local level. It is important for leaders in the UK to know what resources law enforcement have and where they need training and support in the fight against fraud.

Q. If a company finds itself subject to a government investigation or dawn raid, how should it respond?

A. Any investigation, and especially a raid, can be an incredibly stressful time for a company and its employees. The important thing is to not panic – the investigators have a job to do, and the sooner they get to the truth of the situation, the better for everyone. Companies should direct their management and their employees to cooperate fully, while also engaging legal counsel to properly protect the corporation from future litigation. If fraud is detected, it is a criminal matter and the company should make a good faith effort to work with prosecutors and regulators, while making sure to document all control measures and prior steps taken to manage fraud risk. Having a track record of meeting compliance requirements and having proper internal controls in place at the time fraud occurs could have a mitigating effect in terms of potential prosecution and penalties down the road.

Q. What role are whistleblowers playing in the fight against corporate fraud and corruption? How important is it to train staff to identify and report potentially fraudulent activity?

A. Employees are a company’s first line of defence against fraud and corruption. But training them to recognise the red flags of fraud is only half of the process. The company must also implement a reporting system that is anonymous and easy to use, so that employees are encouraged to report any suspicions. Then, the company must follow through and fully investigate any reports that do come in. If it does not, whistleblowers will believe that combatting fraud and corruption is not a corporate priority, and the tips will stop coming in. How important are those tips? According to the ACFE, they are by far the highest detection method for fraud, well above audits and other means. The company should communicate that a whistleblower hotline or online reporting system is available, and that there is a zero-tolerance policy for any type of retaliation against whistleblowers. Over time, the tips will come in.

Q. What advice can you offer to companies on conducting an internal investigation to follow up on suspicions of fraud or corruption?

A. Investigations can be challenging, and they require expertise. For example, there are rules for collecting and handling evidence, including physical evidence and witness statements, that must be followed for such evidence to be admissible in court. There are also laws in the UK dealing with privacy and the rights of the accused. The bottom line is that a company already dealing with a potentially costly and damaging fraud scenario should not risk adding more legal trouble through a faulty investigation. Hire experts who deal with corporate crime and specialise in fraud and corruption cases. Like any other area of expertise, they will have the knowledge and resources to help proceed with an investigation and lead it to the most favourable outcome for your company. If you already have anti-fraud professionals on staff, let them take the lead, but provide outside resources as needed.

Q. What general steps can companies take to proactively prevent corruption and fraud within their organisation?

A. A fraud prevention strategy has many different elements, and the sooner companies implement them, the sooner they can begin to work together in a proactive way to prevent fraud. Mandating employee training, such as ISO 37001 ABMS, having an ethical code of conduct signed by every member of staff, providing regular and surprise audits, and implementing a fraud reporting system are all effective ways to help prevent and detect fraud and corruption. None of these methods is strong enough on its own to properly protect organisations. But together, they can be very effective. It is also important to set a ‘tone at the top’, from ownership, directors and management on down, that fraud will not be tolerated. Anti-fraud controls only work if the company sees them through and thoroughly investigates every report. When fraud is confirmed, any perpetrators should be terminated and potentially prosecuted, sending a message of zerotolerance.

Meet HUMA KHALID,  Scheme Manager

Huma Khalid, as scheme manager, is responsible for leading ABAC. Ms Khalid’s responsibilities include planning and overseeing all aspects of the ABAC programme, which include certification and training. Additionally, she oversees the compliance department for the implementation, management and internal audit of CRI Group’s and ABAC compliance programmes

ABAC™ Center of Excellence Limited | t: +44 (0)777 652 4355 | e: huma.k@abacgroup.com

About 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 Intelligence, Due 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.

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