In Krolls 2015 ABC Report, Kroll asked respondents to identify what they considered to be the type of corrupt behavior the chief compliance officer must guard against.
The primary answers are
- bribery (93%),
- money laundering (61%),
- bid-rigging (60%), and
- price fixing (56%).
Trailing further behind “the big four” corruption risks are
- conflict minerals (27%) and
- human trafficking (26%).
When focusing on the main concern — bribery — best practice is to incorporate six principles:
- proportionality,
- top level commitment,
- organizational risk assessment,
- due diligence,
- communication, and
- monitoring
These principles form a framework for assessing relevant
- policies,
- procedures and
- controls
Typically, the types of misconduct uncovered during bribery risk assessments include:
- Slush funds that enable off-books payments by agents
- Agent payments to foreign officials
- Concealment of bribes to foreign officials
- Agents providing goods and services to a charitable group owned or operated by a foreign official as a bribe, and
- Misappropriation of funds due to control weaknesses.
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