Anti-Corruption and Ethics
Our team of senior compliance advisors and executives provides top tier compliance consulting services to clients on an as-needed, project or part-time basis. The following are aspects of CRC’s Anti-Corruption & Ethics services, which is merely a small part of the comprehensive Compliance Risk Management Programs that we offer across many industry verticals.
Aspects Of Anti-Corruption & Ethics
Build/Review/Improve Overall Compliance Program
According to the client’s needs, CRC builds, reviews, and/or makes recommendations to improve a company’s overall compliance program. This service includes performing a risk assessment and gap analysis of current offerings to prevent, detect, and remediate compliance failures. CRC offers a multitude of solutions to address any detected gaps.
Build/Review/Improve FCPA/Anti-Corruption Program
According to the client’s needs, CRC builds, reviews, and/or makes recommendations to improve a company’s FCPA/anti-corruption program. This service includes performing a risk analysis and gap analysis of current offerings to prevent, detect, and remediate weaknesses. CRC offers a multitude of solutions to address any detected gaps.
Anti-Fraud and Ethics Policies, Procedures and Best Practices
CRC drafts tailored policies and procedures to address the client’s needs and any potential concerns. CRC also advises with respect to best practices to enable clients to operate within a safe zone from a regulatory perspective.
Codes of Conduct
CRC drafts and/or brings existing Codes up to best modern-day practices. This work may entail gap analyses, cultural surveys, updated formats, and visual aids.
Third-Party Due Diligence Approaches and Reviews
CRC helps its clients construct and develop risk-based solutions to third party risks. With the most challenging third parties, CRC assists its clients with deep-dive diligence to help determine whether or not business can safely proceed.
Internal Corruption Preventative Tactics and Investigations
CRC advises its clients with respect to best practices, to minimize the incidences of internal corrupt practices and their accompanying risks. CRC also conducts internal investigations to help clients determine whether fraud occurred and, if so, the full extent of the conduct along with the participants.
FCPA Programs and Violation Investigations
CRC conducts internal investigations to help clients determine whether an FCPA violation may have occurred and, if so, the full extent of the conduct along with the participants.
Fraud, Corruption and FCPA Risk Analyses
CRC conducts risk analyses for its clients to assist them in determining their level of exposure to potentially destabilizing risk. CRC offers tailored solutions to what is found.
Internal Control Programs
CRC assists clients with devising and implementing internal controls to ensure an effective compliance program.
M&A Corruption Due Diligence
CRC helps guide clients with devising effective approaches to M&A FCPA due diligence, and assists with the cost-effective execution thereof.
Guidance on Engaging with Regulators
Whether before, during, or after engaging with regulators, clients benefit from the depth of CRC’s extensive in-house and DOJ experience. In an affordable fashion, CRC helps companies make effective and business-friendly adjustments to their programs to minimize the likelihood of, and severity of, disruptive and impactful government encounters.
Conflict of Interest Questionnaires and Assessments
CRC assists clients with determining whether undetected conflicts exist within their organization. CRC can manage the process from assessing risk, to drafting pertinent questionnaires.
Ethical Culture Surveys
A company’s culture drives the employees’ collective behaviors. A cultural tolerance for unethical conduct can lead to fraud and related behavior that in the worst instances leads to damaging fines and management distraction. CRC’s ethical culture surveys assist our clients with determining the true underlying culture and the risks that are presented. CRC offers solutions to address these risks.
Anti-Fraud, Anti-Corruption and Ethics Training
CRC offers a full suite of training materials in the critical areas of fraud, corruption and ethics. CRC can provide this training via a former in-house CCO with DOJ experience, who speaks from a real-world, battle-tested and business-friendly perspective.
ISO 37001 Anti-Bribery Program Assessments
Companies contemplating ISO 37001 certification benefit from CRC’s assessment of their program. CRC will help the client identify areas in their program that may be lacking, and make recommended improvements to lead to certification.