We believe, and experience shows, that most anti-corruption problems can be prevented by understanding risks and putting the right compliance programs in place. As businesses evolve, their risks evolve. Staying ahead of those risks is critical. This is why regulators in both the U.S. and abroad repeatedly underscore the importance of thoughtful and regularly-updated risk assessments as an essential component of any compliance program.

Understanding current and developing risks enables companies to make informed and practical decisions about what policies and procedures are necessary and what resources are needed to implement them effectively. Assessing evolving risks also informs the appropriate approach to effective compliance training such as the audience, content, frequency, and delivery system. Having a risk-based and appropriately tailored compliance program not only decreases the likelihood that problems will arise, but also places companies in the best position possible to detect and remediate problems if an issue does surface. Besides protecting a company’s reputation, this will also demonstrate to regulators that a company takes compliance with the law seriously.

  • Risk Assessments: We regularly conduct global assessments to help clients understand their corruption related risks on an enterprise-wide basis. We have undertaken risk assessments for companies in many industries, including professional services, energy, consumer products, construction, technology, hospitality, defense and aerospace, media and entertainment, and transportation, among others. Our global footprint allows us to use teams efficiently on the ground in different geographies, where appropriate, to conduct interviews and interface with our clients’ personnel. We help our clients identify areas of risk, including:
    • industry and geographic risk factors;
    • government touch points and interactions, including customs, trade, licensing, and regulation;
    • employees and third parties engaging with government officials;
    • gifts, entertainment, and travel practices;
    • charitable giving, political donations, and professional sponsorships; and
    • marketing practices and sales and distribution models.
  • Designing Compliance ProgramsBased on our risk assessment, we help companies develop and implement tailored improvements to their anti-corruption compliance programs. Depending on the particular needs of the company, this may include detailed codes of conduct and specific anti-corruption policies and procedures covering gifts, travel, and entertainment, charitable giving, third parties (including agents, distributors, and suppliers), transactional due diligence, whistleblowers, disciplinary and incentive measures, and compliance auditing, among others.
  • Benchmarking and Testing Compliance Programs:  We help our clients develop plans for testing and monitoring the effectiveness of compliance programs, from both a quantitative and qualitative perspective, and help clients determine how best to leverage internal resources, such as internal audit, to assist with this process. We also help our clients review and improve internal accounting controls and establish proper systems to internally investigate potential issues. We are also well-positioned to help clients benchmark their compliance program against peer companies and to assess the regulators’ likely reaction to the sufficiency of their compliance programs.
  • TrainingWe routinely design, review, and deliver anti-corruption compliance training for clients in numerous languages across the globe and to employees at all levels, including senior executive managers, directors, and sales representatives.

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