Anti-Bribery and Corruption (ABC) Investigations and Compliance

Anti-bribery and anti-corruption (ABC) enforcement actions have reached unprecedented heights in recent years. Placing increased pressure on companies to investigate any indication of bribery and corruption in their organization, regulators and law enforcement authorities across the globe are clamping down on bribery and corruption and revolutionizing cross-border collaboration. While ABC laws and regulations are industry agnostic, enforcement activities are often focused on certain highly regulated sectors including, but not limited to, financial services, medical devices, pharmaceuticals, telecoms, technology, and oil and gas. Heavy emphasis has also been placed on the operational effectiveness of ABC programs and controls with respect to business partners and third parties.

In the end, the true costs to a corporation of bribery or corruption go well beyond any monetary penalty. The reputational damage caused by such an enforcement action can seriously damage an organization.

ABC Investigations

K2 Integrity’s multidisciplinary team of subject-matter experts are often called on after an incident or allegation of bribery or corruption occurs to investigate the incident and root out any problems. We quickly assess the incident, contain it, and help our client communicate with regulators, working closely with in-house and external legal counsel.

Our approach to bribery and corruption investigations combines forensic and investigative accounting skillsets with cutting-edge forensic technology, data analytics, and the ability to identify and obtain relevant external intelligence and evidence. Our investigators are skilled interviewers and able to obtain maximum value from interviews that may be conducted at different stages of the investigation.

ABC Compliance Solutions

We take pride in providing our clients with practical and cost-effective ABC compliance solutions, including the development of ABC programs and controls for organizations of all sizes and complexity. Our approach is driven by regulatory guidance suggesting right-sized, risk-based ABC programs. Our insights into the effectiveness of industry-specific ABC risks and controls allow us to efficiently assess, design, and operationalize ABC programs and controls.

In our ABC risk assessments, we identify the inherent bribery risks to which our client could be exposed according to the nature and location of its activities, identify the activities and risk factors that could increase the client’s exposure to bribery risk, and evaluate the risks. The output is used to highlight areas where the client’s ABC controls can be improved.

Whether we are building from the bottom up or starting with an existing set of policies, we strive to integrate our client’s ABC policies and controls into the organization’s overall compliance program.

An effective ABC program starts with the proper tone and culture, as well as the appropriate governance and compliance infrastructure. We help our clients to ensure that management, boards, and audit committees have mechanisms in place for effective oversight of ABC programs, and that compliance officers have the tools they need to ensure effective risk mitigation. This includes ABC compliance infrastructure and systems, resources, reporting mechanisms, training, and communication.

Our services are broken out into three main areas:

Assessment

  • ABC risk assessments
  • ABC compliance program gap analysis
  • Third-party ABC risk assessments

Prevention and Detection

  • Design of ABC policies and procedures
  • Development of ABC controls
  • Development of ABC monitoring program and data analytics
  • Third-party ABC audits
  • Third-party ABC due diligence

Response

  • Independent investigations
  • ABC remediation
  • ABC monitorships