Discuss how you would develop a work plan to investigate whistleblower allegations of bribery and kickbacks.

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Discuss how you would develop a work plan to investigate whistleblower allegations of bribery and kickbacks.

Discussion: Investigating Allegations of Bribery and Kickbacks

Requirement:
250 Words
Only use materials provided for references purposes
APA Format

Introduction

The investigation of bribery and corruption can involve multiple jurisdictions and multiple allegations against large companies with complex organizational structures. Therefore, the investigation plan needs to be well thought out and planned to cover all the allegations and all of the locations that the investigation team is aware of.  The investigation plan must also cover all the potential bribery and corruption schemes to be examined. This plan should include procedures for financial testing, interviewing, public record searches and data analytics.

Special Investigations Part 1

Performing whistle-blower Investigations into allegations of bribery and corruption can be a daunting task that requires the coordination of many special skills and disciplines inside and outside of the organization. These type of investigations are highly sensitive and require extreme professionalism because the stakes can be extremely high for the company officers, board directors and organizations involved.

Special Investigations Part 2-Interviewing

HOW TO CONDUCT AN INTERNAL INVESTIGATION
Bill Olsen – Module #6

Module Agenda

  • The appropriate response to fraud
  • Planning the fraud investigation
  • The interview – A conversation with a purpose
  • The interrogation – Eliciting information that one is attempting to withhold
  • Other investigative techniques
  • Communication of findings

 

The appropriate response to fraud

  • Act fast
  • Gather the fact
  • Identify contributing factor
  • Interview witnesses
  • Interview the perpetrator
  • Proper disciplinary action
  • Educate the organization

The appropriate response to fraud

  • Act fast:
    ➢ Inform the board and management
    ➢ Make proper notifications
    ➢ Isolate the suspect
    ➢ Secure electronic evidence

The appropriate response to fraud

  • Gather the facts:
    ➢ Develop investigation plan
    ➢ Question relevant personnel
    ➢ Collect data
    ➢ Perform financial analysis

Today’s Agenda

 The appropriate response to fraud

  • Planning the fraud investigation
  • The interview – A conversation with a purpose
  • The interrogation – Eliciting information that one is attempting to withhold
  • Other investigative techniques
  • Communication of findingsPlanning the fraud investigation
    fraud
    Suspected fraud vs. investigation assertions of

➢Predication
based on reliable information
Establishing that the fraud allegations are
➢By the investigation
reputation damage and defamation caused
Helps protect from legal complaints such as

 

Planning the fraud investigatio

  • Written vs. oral – draft memo of initial
    investigation and obtain a signature if possible.
  • allegations are preferable to support the
    meeting with the whistleblower. Written
    alleged fraud and the bases of the allegations
  • State the nature and factual aspects of the
    are obtained during the investigation

Modify the information if additional indicia

Planning the fraud investigation Things to consider

  • Independence and objectivity
  • Conflict checks
  • Background check
  • Confidentiality
  • Privilege

Communication

Planning the fraud investigation
(cont.)Things to consider

  • Staffing (CFE, CPA)
  • Technology skills
  • Industry knowledge
  • Language skills
  • Legal
  • Human Resources

Planning the fraud investigation Develop a phased work plan

  • Public record searches
  • Computer forensics
  • Develop interview questions
  • Develop interview list (proper sequencing)
  • Identify documents to be reviewed
  • What needs to be proven
  • Understanding of the allegations
  • Understanding of fraudulent schemes
  • Understanding of underlying processes
  • Examine motivation of suspects
  • When did the activity start
  • How much money is involvedPlanning the fraud investigation Investigative and interviewing– The basics
  • Evidence preservation and security
  • Chain of custody
  • Special issues for computers
  • Voice mail, e-mail, phone logs, cameras
  • Limit access to systems once the investigation is knownPlanning the fraud investigation Investigative planning
  • Alerts suspect to the investigation
  • Allows suspect time to come up with alibi
  • Destruction of evidence
  • Alerts co-conspirators
  • A lack of coordinated response
  • Can create legal exposure for client
  • Can create legal exposure for your organizationPlanning the fraud investigation Consequences of poor planning
    Today’s Agenda
  • The appropriate response to fraud
  • Planning the fraud investigation
  • The interview – A conversation with a purpose
  • The interrogation – Eliciting information that one is attempting to withhold
  • Other investigative technique
  • Communication of findings
  • The appropriate response to fraud
  • Act fast
  • Gather the facts
  • Identify contributing factors
  • Interview witnesses
  • Interview the perpetrator
  • Proper disciplinary action
  • Educate the organization

The appropriate response to fraud
• Act fast:
➢ Inform the board and management
➢ Make proper notifications
➢ Isolate the suspect
➢ Secure electronic evidence

The appropriate response to fraud
• Gather the facts:
➢ Develop investigation plan
➢ Question relevant personnel
➢ Collect data
➢ Perform financial analysis

  • Today’s Agenda•
  • The appropriate response to fraud
  • Planning the fraud investigation
  • The interview – A conversation with a purpose
  • The interrogation – Eliciting information that
    one is attempting to withhold
  • Other investigative techniques
  • Communication of findings