Fraud: Corporate fraud, employee theft, insurance scams/workers compensation fraud, employer fraud, forgery/falsified documents and even money laundering. Nobody likes to think it’s happening in their company, and yet global fraud studies by the Association of Certified Fraud Examiners (ACFE) estimate a median of 5% of revenue is lost every year due to fraud. While the ACFE found that both large and small organizations fall victim to occupational and workplace fraud, employee theft and financial fraud are especially detrimental to businesses with less than 100 employees.
This week, the Association of Certified Fraud Examiners (ACFE) is doing its part to bring the issue of fraud to the forefront with its sixth-annual International Fraud Awareness Week.
Expectations for transaction monitoring (TM) governance are quickly evolving due to the complexity of detection systems, the demand for additional operational oversight, increased regulatory scrutiny, and the need for an adequate control framework to guarantee proper risk management.
A well-designed transaction monitoring (TM) system is an important component of an effective anti-money laundering (AML) compliance program. It supports efforts to combat money laundering and terrorist financing by helping financial institutions identify unusual or suspicious activity that must be reported to regulatory authorities, and aids law enforcement in tracking and prosecuting criminals involved in money laundering and terrorist financing.
In November 2012, the criminal division of the U.S. Department of Justice (DOJ) and the enforcement division of the U.S. Securities and Exchange Commission (SEC) jointly released A Resource Guide to the U.S. Foreign Corrupt Practices Act (“the Guide”). While the 130-page guide is packed with useful information and written in an approachable style free from legalese, it provides perhaps its best and most useful information beginning on page 57 in the section titled, “Hallmarks of an Effective Compliance Program.” In the in introduction to this section, the authors note that there is no such thing as a one-size-fits-all compliance program, and that it is expected that small to midsize companies’ compliance programs will very likely differ from those in place at much larger organizations. They also point out that companies may consider a variety of factors in tailoring a compliance program to their specific organizations.
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