Background Investigations: One-on-one interview with Zafar Anjum
Background Investigations: One-on-one Interview with Zafar Anjum
Having dedicated his career to a background investigation, fraud prevention, protective integrity, security and compliance, Zafar Anjum is a distinguished and highly respected professional in his field. As Group Chief Executive Officer (CEO) at Corporate Research and Investigations Limited (CRI Group™), he uses his extensive knowledge and expertise in creating stable and secure networks across challenging global markets. For organisations needing comprehensive project management, security, safeguard testing, background investigations and real-time compliance applications, Anjum is the assurance expert of choice for industry professionals.
Q: To what extent have you seen an increase in corporate fraud in recent years? What are some of the common themes and underlying causes?
Anjum: Fraud always seems to be increasing. No matter how sophisticated our attempts to prevent it become, perpetrators are always adapting with new methods. According to the 2020 Association of Certified Fraud Examiners (ACFE) Report to the nations, asset misappropriation is the leading type of occupational fraud. It makes up 86% of fraud cases and causes a median loss of $100,000. On the other spectrum, financial statement fraud schemes are the least common (10% of cases) but are the most costly, causing a median loss of $954,000. A typical fraud case can last 14 months before detection and cause a loss of $8,300 per month – a whopping 5% of an organisations revenue is lost to fraud each year. There are various factors at play here, but it starts with ‘tone at the top’. Basically, corporate culture often sets the tone for how strict or lax an organisation prevents or detects fraud. Combine a lax approach with a country or jurisdiction where corruption is still prevalent, even considered ‘business as usual, and there will likely be a fraud.
Q: Could you outline the benefits of using background investigations to reduce potential fraud? Under what circumstances is it prudent to undertake a background investigation?
Anjum: It should be a priority to conduct thorough background investigations when engaging in a merger or acquisition, an initial public offering (IPO), engaging suppliers, contractors or new clients – your client relationships can affect your organisation’s reputation and your ability – to name a few situations. This can help you avoid becoming entangled with third parties that have hidden fraud and other legal issues. It will also make you aware of a potential partner who has credit risk, has claimed bankruptcy or is faced with debtor filings, for example. In one case, a company was seeking to engage a new supplier for medical supplies and equipment. A background investigation revealed that the warehouse’s physical location – claimed by this ‘supplier’ did not exist. The company’s principal had previously been charged with a ‘criminal breach of trust’. Three other civil damages claims against the principal were discovered, with millions claimed in liabilities.
Q: What are some of the best practice approaches to conducting a background investigation?
Anjum: One of the most important aspects of thorough background investigations is having a ‘boots on the ground approach. Online database searches can only take you so far. When conducting due diligence on entities or individuals, red flags that pop up often warrant further checking before they can be truly weighed as part of the decision process. For example, if you are considering partnering with another company and providing information for their physical location, do you have agents who can visit that location to make sure it is legitimate? Investigations sometimes discover that purported ‘headquarters’ is actually an abandoned home or vacant lot. Also, if certain credentials are claimed, you need to make phone calls or possibly a visit to the school or accrediting bodies to verify them. These are the important details that help you with facts that help guide your decisions.
EFFECTIVE RISK MANAGEMENT THROUGH BACKGROUND INVESTIGATIONS. FIND OUT HERE
Q: What kinds of legal or regulatory issues might complicate a background investigation?
Anjum: Privacy laws are probably the most important issue, and they need to be carefully understood and followed for every jurisdiction. In the UK, for example, the pandemic has created new data privacy issues, but prudent organisations are constantly evaluating their data protection strategies under the General Data Protection Regulation (GDPR). When it comes to background investigations, similar privacy considerations apply. You might want to check an individuals’ financial or credit history – relevant information if they own a business you seek to partner with or acquire, or if you are considering them for a high-level position at your organisation. Accessing such information is permitted in some jurisdictions and restricted by law in others. The last thing you want is to end up in court for violating someone’s privacy. It is best to engage a professional due diligence background screening firm. They will be trained and up-to-date on the laws governing your background investigations, plus they will have access to resources that most companies do not have.
Q: To what extent are background investigations more challenging in a cross-border or multi-jurisdictional context? How can these additional challenges be overcome or avoided?
Anjum: This goes back to the importance of having investigators in various locations, your ‘boots on the ground’, in your approach to due diligence. The world is much smaller these days as organisations seek to expand across international borders. And the COVID-19 is teaching leaders invaluable lessons in business efficiencies and future strategy. This can lead to obvious challenges – both following the laws and regulations in various jurisdictions and overcoming language and cultural barriers. That is why it is important to have access to locally-based agents – including certified fraud examiners and similarly credentialed professionals – to help with your checks, whether investigating a potential third-party partner or an individual being considered for employment. Another advantage is to have a set, written policy and process for conducting background investigations that you can reference and rely upon when undertaking key business decisions. In this way, your organisation is less susceptible to someone convincing you to bypass proper due diligence simply because it might seem logistically difficult to conduct an overseas investigation.
MITIGATE EMPLOYEE RISK BEFORE & AFTER HIRE? LEARN MORE HERE
Q: Once the background investigation results are collated, what are the key points to analysing?
Anjum: If red flags are uncovered, the best way to further investigate is to understand discrepancies. For example, suppose you are conducting background screening on a potential employee, and something comes up in their criminal record, rather than eliminating them from consideration. In that case, you should ensure that there was no error in your background check, investigate the discrepancy, gather all relevant information, and ask the person to explain what you found and why they did not disclose it. They might have an explanation that affects your decision process. In other words, do not overlook potential talent. According to Nacro, more than 11 million people in the UK have a criminal record – that’s 1 in 3 men – however, just over half of these had been convicted on only one occasion, and 85% were convicted before they were 30 years old. Not all of those have a prison record, however. Most convictions are for motoring offences, such as speeding or unpaid tickets.
Q: What essential advice would you offer to companies on developing internal policies and processes to combat fraud? should intensive background investigations form part of their standard procedures?
Anjum: Intensive background investigations should be a part of an organisation’s standard procedures. It should be part of a greater risk management plan, be set forth as written policy that owners and directors approve, and be reviewed and understood by management and other relevant personnel. Engage risk management professionals when developing your policies and procedures. They can help tailor a plan based o your organisation. Key questions to address should include; who will implement the plan, how an investigation is conducted, who evaluates and reports the results, etc. Sometimes organisations put forth a thorough, excellent programme for background investigations and then, six months or a year later, nobody is following it. The key to success is following through with it and ensuring your entire organisation understands the process and why it is so important. The security of your company depends on effective risk management.
The security of your company depends on effective risk management
Background investigations are critical to any company’s success because working with qualified, honest and hard-working employees and other businesses is integral to thriving in the business community. What you don’t know can hurt you, and the simple act of one bad decision can result in an unprecedented loss for your company.
From vendor and third-party screening to employment screening, CRI Group™ recommends background investigations as critical proactive measures to help keep your business safe. An effective background screening investigation will help screen for bad apples that can cause havoc down the road. Because we maintain a diverse talent base comprised of multilingual and multi-cultural professionals, CRI™ can traverse obstacles that often impede international background investigations. That’s why we are frequently contracted by our competitors to conduct background investigations in geographic regions not serviced or accessible by larger investigative firms.
Meet our 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 businesses 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 safeguards 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
37th Floor, 1 Canada Square, Canary Wharf, London, E14 5AA United Kingdom e: zanjum@crigroup.com | LinkedIn | Schedule a meeting | t: +44 207 8681415 | m: +44 7588 454959
CRI™ Named Certified Provider by HRO Today Association
CRI Group™ has been approved by the HRO Today Association as a Certified Provider to the human resources services industry. CRI Group™ completed a rigorous audit process and “demonstrated a high level of accountability of standards and ethics,” according to an HRO Today Association statement.
“The HRO Today Association has long been the HR industry’s standard-setting organisation,” said Renee Preston, Global Executive Director of the HRO Today Association. “We are pleased to add CRI Group™ to the growing list of certified providers who are dedicated to offering the highest level of service to the HR community.”
“We are extremely proud to be recognised by HRO Today Association for our diligence and rigorous processes to ensure best practices across organisations,” Anjum said. “At CRI Group™, we share the vision with HRO Today Association that shifting demographics and increased globalisation means that human resources truly lead from the front among employers, candidates and customers,” Anjum said.
Established in 1990, CRI Group™ is a leading global provider of expert employee background screening services. Serving clients worldwide, CRI Group™ also provides investigative due diligence, third-party risk management, compliance and other professional investigative research services. Addressing a need for thorough pre- and post-employment background screening, CRI Group™ developed its own EmploySmart™ background screening service to avoid negligent hiring liabilities. EmploySmart™ can be tailored into specific screening packages to meet the requirements of each specific position within an organisation.
Proper pre-employment checks can reduce the risk of hiring someone who could cause irrevocable damage. Zafar Anjum, founder and CEO of CRI Group™, said “Firms spend years, thousands, even millions to brand their products and services, and one bad hire can cause loss of capital and reputation. EmploySmart™ focuses on using best practices, technological solutions, and a ‘boots on the ground’ approach to provide the best possible background screening for clients.”
About HRO Today Provider Certification Program
HRO Today Association certified members demonstrate that they have undergone evaluation and testing to verify themselves as credible and trusted providers. This form of certification ensures customers have access to qualified service providers in the HR services and technology industry.
Let us know if you would like to learn more
If you have any further questions or interest in implementing compliance solutions, please contact us.
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 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 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.
Meet our CEO
Zafar I. Anjum is Group Chief Executive Officer of CRI Group™, a global supplier of investigative, forensic accounting, business due to diligence and employee background screening services for some of the world’s leading business organizations. 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, Estonia, Turkey, 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
An Open End-of-Year Appreciation Letter
An Open End-of-Year Appreciation Letter
As the end of the year draws near, we would like to take this opportunity to thank all of you for a fantastic year. The success of the CRI™ Group is based on the relationships we have built over the years, and we really wouldn’t be where we are without you. We are grateful for the opportunity to work with and for you.
Our passion for safeguarding the corporate world by detecting and exposing those elements that can cause irreparable harm to a business and help markets stand up against the outside forces that, through corruption, collusion, coercion and fraud, can cause financial, organisational, reputational and legal harm to our global clients remains strong. Over this past year, we have added staff, contractors and new clients to help us on our mission.
At CRI®, we are committed to spreading knowledge about the negative impact of fraud on global businesses and promoting transparent business relations across the world. For the past year, we worked extensively to deliver whitepapers, manuals and other insights to help organisations overcome bribery and corruption challenges and manage risks more effectively. 2021 was a year that brought many industry collaborations – including events hosted with several experts from leading organisations – and educated over 600 people with:
- Live webinar on “Third-party Due Diligence & Oversight” with Malaysian International Chamber of Commerce & Industry (MICCI) to celebrate International Anti-Corruption Day.
- Live Webinar on “Compliance & Adequate Due Diligence for Third-Party Risk Management – An Essential Part of a Corporate Compliance Program” hosted by us and Dubai Quality Group (DQG) with Samia El Kadiri, a Governance & Compliance Consultant for Hawkamah Institute for Corporate Governance (DIFC) and renowned author as guest speaker
- Live debate/discussion on “Reporting bribery and misconduct in the workplace. Know-how you can be the whistleblower!– building a better whistleblowing mechanism by adopting ISO 37002:2021″ with Tuan Haji Mohd Nur Lokman Samingan, MACC Senior Assistant Commissioner & Head Private Sector Branch Community Education Division and Dr KM Loi, President – Association of ABMS Practitioners Malaysia.
- Live webinar on “Bribery Pitfalls Most Organisations Often Commit. The Importance of Anti-Bribery Management Systems (ABMS)” with Dato” Sri Akhbar Haji Satar, CFE, AIBM, Founder, President Association of Certified Fraud Examiners (Malaysia).
- Live debate on “Bribery discovered: What to do in the next 48 hours? with Robert Youill, Executive Director from Key Risk Consulting Asia as a guest speaker; and
- Live webinar on “Protecting your company from the global corruption pandemic“, where we explored case studies, discussed and compared local, regional and global corporate compliance standards and legislations.
2021 has been filled with a multitude of victories, and 2022 is set to be even better, as Zafar I. Anjum, our Group Chief Executive Officer, comments on here:
“2021 saw an expansion in our service capabilities with our 3PRM™- Certified solution, Anti-Money Laundering Advisory services and BS 7858:2019 Screening investigations solutions (CRI® is the only BS 7858 certified background screening services provider in the UAE and across the Middle East); in addition to announcing the opening of our new offices in Turkey (Corporate Research and Investigations Danışmanlık Hizmetleri Limited Şirketi).”
“Our sales and marketing teams have been busy attending exhibitions. We’ve also seen a dramatic increase in our online marketing presence and subsequent engagement with our customers. Next year we hope to build on the success of 2021, and to that end, further expansion plans are already on the drawing board.”
“It just leaves me to thank all our customers for their business and loyalty, but perhaps most importantly all of the hard-working and dedicated employees in the UK, UAE, Qatar, Singapore, Malaysia, Pakistan and USA, without whom none of what you read in the subsequent pages would be possible. Thank you, and here’s to a successful 2022.”
On behalf of CRI Group™, we wish you a very Merry Christmas and a wonderful holiday season! Thank you for your continued support and partnership. We look forward to working with you in the years to come.
CRI™ Celebrates 2021 International Anti-Corruption Day
CRI™ celebrates 2021 International Anti-Corruption Day: Organisations are urged to unite on December 9th for International Anti-Corruption Day
Corruption is the single greatest obstacle to economic and social development around the world. According to the World Bank, every year $1 trillion is paid in bribes, while an estimated $2.6 trillion are stolen annually through corruption – a sum equivalent to more than 5 percent of the global Gross Domestic Product (World Economic Forum).
To help combat this growing problem, Corporate Research and Investigations Limited “CRI Group™” is spreading awareness and encouraging organisations to support the United Nation’s International Anti-Corruption Day, 9 December 2021. CRI Group™ is a global leader in corporate investigations and risk management that serves clients in Europe, Asia Pacific, South Asia, the Middle East, North Africa and North America.
Here is more bad news about corruption:
- Worldwide corporate corruption continues to disrupt socioeconomic progress in developing nations.
- Corruption weakens governments, fuels organised crime, stifles economic growth and discourages development.
- The cost of corruption can have a devastating effect on any business and its stakeholders, from the damaged corporate image, devalued stock, negative public perception, costly legal challenges and even incarceration of corporate directors.
- Organisations are finding it increasingly difficult to navigate the complex web of multi-jurisdictional laws and regulations related to anti-bribery and anti-corruption practices.
CRI Group’s CEO, Zafar Anjum, said that CRI Group™ offers solutions for building global compliance frameworks that safeguard the world’s leading organisations. For example, CRI Group’s Anti-Bribery Anti-Corruption Centre of Excellence provides consulting services to organisations seeking to validate or expand their existing compliance frameworks to maintain a competitive edge in the world marketplace.
Anjum noted that CRI Group™ also offers independent ISO 37001:2016 Anti-Bribery Management System certification to ensure that organisation is in compliance with this newly established standard, which is recognised and practised in more than 160 countries worldwide.
CRI Group’s DueDiligence360™ involves a review of all relevant information pertaining to virtually any business on the planet to ascertain past business dealings, criminal records, executive stability and suspect associations to ensure your organisation is protected from internal threats and outside risks.
CRI Group’s exclusive 3PRM-Certified™ solution provides Third-Party Risk Management while ensuring compliance with FCPA, UK Bribery Act, Anti-Bribery and Anti-Corruption, and other global, regional and local regulations.
Contact CRI Group™ to learn more about preventing and detecting corruption.
Who is CRI Group™?
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.
Q&A: Corporate Fraud & Corruption in the UK 2021
The United Kingdom scores 77 out of 100 on Transparency International’s (TI) 2020 Corruption Perceptions Index (CPI), as is one of the 25 least corrupt countries across the globe. However, it all seems great on the surface as corporate fraud and corruption cases have been noticeable in various industries across the UK. TI reports that corrupt actors enjoy their illicit gains by “buying luxury property in the world’s most sought-after cities, like London”. Based on the article “CPI 2020: Trouble in the top 25 countries”, “While the UK (77) is the first G20 country to launch a public register of beneficial ownership, a loophole in the law allows foreign companies to purchase real estate anonymously. This is particularly problematic as research shows that over 75 per cent of properties subject to criminal investigations between 2004 and 2015 used offshore anonymous companies to hide their owners’ identities. The UK government committed to closing this loophole by introducing a register of beneficial ownership for property, but it has yet to be implemented. The necessary legislation has been subject to significant delays. In the meantime, rich businesspeople linked to autocratic regimes are allegedly purchasing property via shell companies, such as billionaire and daughter of former President of Angola, Isabel de Santos.”
To discuss the situation of corporate fraud and corruption, CRI Group™ and its ABAC™ Center of Excellence were invited to share the expert views in the special InDepth Feature by Financier Worldwide “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, but across the globe, and provide solutions and insights for businesses to become better protected from corporate fraud, bribery and corruption. Read on the answers to the below questions:
- To what extent have you seen a notable rise in the level of corporate fraud, bribery and corruption uncovered in your country of focus?
- Have there been any legal and regulatory changes implemented in your country of focus designed to combat fraud and corruption? What penalties do companies face for failure to comply?
- In your opinion, do regulators in your region have sufficient resources to enforce the law in this area? Are they making inroads?
- If a company finds itself subject to a government investigation or dawn raid, how should it respond?
- 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?
- What advice can you offer to companies on conducting an internal investigation to follow up on suspicions of fraud or corruption?
- What general steps can companies take to proactively prevent corruption and fraud within their organisation?
Q: To what extent have you seen a notable rise in the level of corporate fraud, bribery and corruption uncovered in your country of focus?
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 your country of focus 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 your region 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 four-year 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. View the reprint of the interview, covering not only the UK but also the United Arab Emirates.
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 they do 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 zero-tolerance.
Find out more about the ISO 37001 training
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
Source & Credits
The original version of the Q&A was published on Financier Worldwide’s InDepth Feature: Corporate Fraud & Corruption 2021. Download the reprint here.
CRI®, the only company with BS102000 & BS7858 certifications in Middle East
What is BS7858 & BS102000? The BS7858:2019 standard, “Screening of Individuals Working in a Secure Environment – Code of Practice,” places emphasis on the risk assessment of secure environment workers. The code focuses on the need for tighter controls over the pre-employment screening – and periodic re-screening – of individuals, who in their positions could potentially benefit from illicit personal gain, become compromised, or take advantage of other opportunities for creating breaches of confidentiality, trust or safety. Read more here.
When it comes to providing information security, financial audits, risk assessments, background checks, due diligence and a wide range of anti-fraud related services, maintaining the highest levels of training and expertise is an absolute must. That’s why CRI® Group achieves critical certifications from the British Standards Institute (BSI), the National Association of Background Screeners (NAPBS) and other preeminent groups in the security and anti-fraud field as part of the company’s commitment to its clients.
CRI® Group is the first and only investigative research company in the Middle East to receive the certifications BS102000:2013, Code of Practice for the Provision of Investigative Services, and BS7858:2019, screening of individuals working in a secure environment, from internationally recognised training and certification body BSI. CRI® Group also holds other BSI certifications (more on those within this article).
Founded in 1901, BSI is the UK national standards body that works with thousands of organisations in more than 150 countries. BSI is accredited by 20 local and international bodies. We sat down with CRI® Group President and CEO Zafar I Anjum, CFE, to discuss these certifications and what they mean:
CRI® Group is the only firm of its kind in the Middle East to hold the BS102000:2013 and BS7858:2019 certifications. What led you to embark on gaining these and other certifications from BSI?
Anjum: Just a few years ago, we announced that CRI® Group would be engaging BSI for training and certification on many levels, and these and other certifications are direct results of that initiative. Earning multiple certifications from a distinguished standards body like BSI is a mark of pride for us as it demonstrates expertise in our core services.
BS102000:2013 is the “Code of Practice for the Provision of Investigative Services.” What does this mean?
Anjum: This certifies CRI® Group’s proficiency in providing services regarding fraud risk assessment and investigations, forensic accounting, intellectual property (IP) investigations, due diligence and background investigations, debt collections, corporate security consulting and investigation, pre-and post-employment screening and fraud and crime investigations.
BS7858:2019 denotes “Security Screening of Individuals Employed in a Security Environment.” Please tell us more about this certification.
Anjum: This recognises CRI® Group’s expertise in screening services including identity checks, financial checks, employment checks and criminal records checks. CRI® Group implemented this standard with regular external audits conducted by BSI and adhered to recommendations specifically vetting and conducting employment background screening of security personnel seeking affiliations with security companies.
How does this relate to CRI® Group’s EmploySmart program?
Anjum: Background screening professionals must be on the cutting edge of industry technology and resources – while also staying educated on the changing laws and regulations that govern the field. At CRI® Group, we are proud to provide the most extensive and thorough background screening services as part of our EmploySmart program.
CRI® Group also holds the certifications ISO/IEC 27001:2013, Information Security Management System and you are a credentialed NAPBS (National Association of Professional Background Screeners) Research Provider. Congratulations on these distinguished credentials!
Anjum: Thank you. We are pleased to have our expertise in these areas recognized by BSI, NAPBS and other leading bodies, and we will continue to strive to provide the top level of service for businesses to help them prevent and detect fraud.
BS7858:2019, a new way to mitigate employee risk during COVID-19
The far-reaching impact of the COVID-19 outbreak has affected virtually every business and economic sector worldwide, and depending on the global region, has hampered (on various levels) the ability to conduct proper and thorough background screening investigations. In the United Kingdom and the United Arab Emirates, the countrywide lockdowns forced leaders to close sites and send their workforce home. Many are having to learn how to manged people working from home (WFH) or remotely for the first time. The previous concerns about productivity, privacy and protecting sensitive information only grew more with the practice of WFH. They highlighted the vital importance of pre-employment background screening and background investigations. BS7858:2019: the revised standard for screening individuals working in secure environments offers a complete solution.
Find out how you can mitigate employee risk during this pandemic with BS7858:2019
The revised BS7858:2019 standard enables organisations to demonstrate a commitment to safeguarding their businesses, employees, customers and information utilising widely accepted methods that focus on risk assessment and top-down management involvement in the company’s employment policies and practices. In establishing policies and practices around the standard, organisations can show that they place a high value on hiring individuals who possess integrity. Organisations can then task them with responsibilities designed to keep their co-workers, customers and information safe from the negative forces that have become more prevalent in today’s ever-changing COVID-19 world.
BS7858:2019, everything you need to know and more!
The price of a bad hire has far-reaching consequences for any business, including productivity loss, decreased employee morale, risks to employee safety and increased exposure to costly negligent hiring claims and potentially devastating litigation. The premise behind the standard is to safeguard employers from bad or fraudulent hires. Cases of organisations that forego conducting due diligence on a new hire – especially a hire with high-risk exposure – often end badly for those organisations. At CRI Group we know how important is your background screening to your company’s success and to give you an idea of what is new we have produced this playbook detailing the differences between BS7858:2012 standard and the new BS7858:2019 standard.
Download your “BS7858:2019, everything you need to know and more!” playbook here…
Managing your people through COVID-19
The COVID-19 pandemic is undeniable affecting the world. And the situation is changing at an hourly rate as we go into a second global lockdown. Businesses are having to adapt quickly in order to survive, i.e. cutting steps in their hiring process, and no-one knows how this will play out. However, there are ways you can mitigate the impact, learn how with this FREE ebook. Taken as a whole, this ebook is the perfect primer for any HR professional, business leader and companies looking to avoid employee background screening risks. It provides the tools and knowledge needed to effectively stay ahead of COVID-19. Read the answers to the following questions:
- How to turn the tide’ on coronavirus crisis?;
- COVID-19 Action point checklist;
- Background Screening: Essential Checks;
- 6 steps for good practice in connection with COVID-19;
- 11 Steps to Reduce Personnel Costs;
- COVID-19 General advice;
- How to remove any danger to your business during COVID-19;
- … and more!
Download your “Employee Screening during COVID-19: everything you need to know and more!” FREE ebook here!
Frequently asked questions about background checks
Get answers to frequently asked questions about background checks/screening cost, guidelines, check references etc. This eBook is a compilation of all of the background screening related questions you ever needed answers to:
- Does a candidate have to give consent to process a background check/screening?
- How long does it take to conduct a background check?
- When should I conduct pre-employment checks?
- How often should I screen employees?
- How to collect references and what to ask?
- How much does it cost to conduct background checks?
- What is the difference between employment history verification and employment reference?
- How do I check on entitlement to work?
- How to conduct identity checks?
- What will a financial regulatory check show?
- Is it possible to identify a conflict of interest during checks?
- What is a bankruptcy check?
- What about directorships and shareholding search?
- Can I have access to a criminal watch list?
- Anti-money laundering check?
- Can we conduct FACIS (fraud and abuse control information system) searches?
- … and MORE!
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 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 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 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.
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 organizations. 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
Q&A session with our CEO: United Arab Emirates fighting Fraud and corruption
Middle east corruption is a threat to the world. The United Arab Emirates (UAE) is a land of complex extremes where fabulous wealth and supercars live right next to staggering poverty. This is generally a recipe for fraud and corruption. However UAE has been talking the right steps towards a fraud free future. This Financier Worldwide Q&A session with our CEO discusses United Arab Emirates role in fighting fraud and corruption. Read the answers to the following questions:
- To what extent have you seen a notable rise in the level f corporate fraud, bribery and corruption uncovered in United Arab Emirates in recent years?
- Have there been any legal and regulatory changes implemented in United Arab emirates designed to combat fraud and corruption? What penalties do companies face for failure comply?
- Do regulators in United Arab Emirates have sufficient resources to enforce the law in this area? Are they making inroads in this area?
- If a company finds itself subject to a government investigation or dawn raid, how should it respond?
- and much more…
Q. To what extent have you seen a notable rise in the level of corporate fraud, bribery and corruption uncovered in United Arab Emirates (UAE) in recent years?
ANJUM: Some recent, high profile cases have affected companies and countries in the Middle East. Embraer’s bribery scandal, involving sales of its aircraft, included officials in Saudi Arabia, among others. Further, there have been suspicions of corruption surrounding the awarding of the 2022 FIFA World Cup to Qatar, suspicious which have been worsened by allegations of human rights abuses involving migrant workers. In general, however, it is still issues like data theft, e-commerce fraud, information security and other high tech threats that pose serious risks to organisations in the Middle East. We live in an increasingly connected world, so while anti-fraud laws and controls in one country may be robust, a company might find itself doing business abroad in a location where laws and enforcement are more lax, and risk is heightened.
Q. Have there been any legal and regulatory changes implemented in UAE designed to combat fraud and corruption? What penalties do companies face for failure to comply?
ANJUM: the UAE has a strong reputation for being tough on corruption, and a new law enhances this stance. The recently approved, and highly anticipated, Anti-Commercial Fraud Law will strengthen protections of intellectual property rights (IPR) and will impose stricter penalties anon counterfeiters. For example, a fraud offence related to counterfeiting could now result in up to 2 years in prison, as well as a fine of up to Dh1m. Overall, corruption is still a low risk for companies operating in the UAE. Laws against corruption are enforced, and they cover bribery, facilitation payments, embezzlement and other types of fraud and abuse. However, when concerning the Middle East as a whole, there are indications that fraud and corruption are the rise, which means we must be ever vigilant in protecting investments throughout the region.
Q. In your opinion, do regulators in UAE have sufficient resources to enforce the law in this area and fight corruption? Are they making inroads in this area?
ANJUM: When considering the Middle East region, there can be no ignoring war-ravaged areas like Syria, Iraq, Libya and Yemen. It is an understatement to say that countries embroiled in conflicts and crisis usually do not have the resources or manpower to properly prevent and detect fraud. But according to Transparency international’s most recent Corruption Perceptions Index, a few of the other more stable and affluent countries in the region are experiencing some difficulty preventing fraud, as well. Different factors can contribute to these struggles, be they politics, autocratic leadership, weak laws or judiciary bodies. However, the UAE still ranks as the least corrupt country in the Middle East, and other countries might take heed of the country’s Anti-Commercial Fraud Law and other existing laws, not to mention the UAE’s enforcement measures, as a possible model for future efforts.
Q. If a company finds itself subject to a government fraud and corruption investigation or dawn raid, how should it respond?
ANJUM: A company that finds itself in such as crisis should immediately cooperate with authorities and work quickly to gather the facts. What are the allegations? What is the scope of the investigation? Was the raid expected, or has the company been taken completely by surprise? In the early stages, it is crucial that the company engages in a good-faith effort to be transparent and cooperative. Of course, retaining legal counsel, is a must at this an every stage of an investigation, If an employee or employees have engaged in fraud, the company should support the fact-finding process and let justice run its course. Company leaders should also evaluate their internal controls and ensure that additional fraud or corruption is not occurring under the radar.
Q. What role are whistle-blowers playing in the fight against corporate fraud and corruption? How important is it to train staff to identify and report potentially fraudulent activity?
ANJUM: The statistics on fraud, such as in the Association of Certified Fraud Examiners Report to the Nation on Occupational Fraud & Abuse show that fraud is most often uncovered by tips, more so than audits, surveillance, account reconciliation, document examination and other methods. Accordingly, a company’s own employees are their first line of defence against fraud. But to encourage whistle blowing, two critical measures need to be in place. First, employee should be trained to identify the red flags of fraud, and to know what does, and what does not, constitute fraudulent behaviour. Second, a reporting mechanism should be in place; an anonymous system by which whistle-blowers can submit their tips without fear of retaliation or negative consequences.
Q. What advice can you offer to companies on conducting an internal investigation to follow up on suspicions of fraud or corruption?
ANJUM: In any situation where fraud is suspected, it is crucial that experts be brought in as quickly as possible to help unravel the facts of the case, if the company does not have anti-fraud professional among its staff, It is critical to remember that there are various laws, depending on your country or region, which govern the rules of gathering evidence and interviewing witnesses. Any evidence that is mishandled or collected improperly can negatively impact an investigation and hurt the chances of a resolution. If an investigation is bungled from the start, it is nearly impossible to then ‘wind it back’ and correct mistakes later. Also, if criminal behaviour is suspected, legal authorities should be quickly notified and provided with the company’s findings and reasons for the allegation.
Q. What general steps can companies take to proactively prevent corruption and fraud within their organisation?
ANJUM: Every organisation, large or small, should have a plan in place for preventing and detecting fraud. The first step is to communicate the organisation’s zero-tolerance stance against fraud. An ethical code of conduct, signed by every employee, can be effective in this regard. A fraud risk assessment should be conducted to find vulnerabilities. The company’s hiring policy should include pre- and post-employment background screening. Job responsibilities should include segregation of duties, so that no single employee has too much control over finances or assets. The company should conduct audits and encourage whistle-blowing with an anonymous reporting system. With a comprehensive fraud prevention system in place, business owners can sleep a little easier, knowing that their organisation has reduced risk and increased their ability to prevent and detect fraud.
Speak up – report any illegal, unethical, or improper behaviour
If you find yourself in an ethical dilemma or suspect inappropriate or illegal conduct, and you feel uncomfortable reporting through normal channels of communication, or wish to raise the issue anonymously, use CRI® Group’s Compliance Hotline. The Compliance Hotline is a secure and confidential reporting channel managed by an independent provider. When reporting a concern in good faith, you will be protected by CRI® Group’s Non-Retaliation Policy.
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.
Meet our CEO
Zafar I. Anjum, is Group Chief Executive Officer of CRI® Group (www.crigroup.com), a global supplier of investigative, forensic accounting, business due diligence and employee background screening services for some of the world’s leading business organisations. Headquartered in London (with 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 safeguards 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, Turkey, Singapore, Malaysia, Brazil, China, 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
This Q&A article is based on a 2017 Financier Worldwide interview.
Since 2001, Financier Worldwide has provided valuable information on corporate finance and board-level business issues through its monthly magazine and exclusive website content. As a leading publisher of news and analysis on this dynamic global market, the organisation is recognised as a valued source of intelligence to the corporate, investment and advisory community. More from Financier Worldwide:
- Corporate resilience: managing third party risks, April 2013 | SPECIAL REPORT: MANAGING RISK
- Contract fraud: is your organisation at risk?, February 2013 | SPECIAL REPORT: CORPORATE FRAUD & CORRUPTION
- Fraud & Regulatory Enforcement 2013, April 2013 | FRAUD & CORRUPTION
Download 2018 annual reviews by Mr. Zafar Anjum, CEO, and Ms. Fatima Farrukh, Compliance professional at CRI® Group.
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Email: info@crigroup.com
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