Forensic Advisory

Third Party Integrity Due Diligence

Integrity Due Diligence (“IDD”) is the gathering of independent information to gain an understanding of the integrity and corruption risks associated with a third party. It provides companies with a means to both identify these risks and confirm (or otherwise) information provided to them by a third party.

Deloitte’s dedicated IDD team comprises over 250 specialist professionals worldwide who speak more than 85 languages fluently, and has extensive experience of conducting timely and cost-effective IDD on a large number of third parties. We do not believe in a ‘one size fits all’ solution and instead we offer our clients several different ‘levels’ of search, enabling our client to choose the level proportionate to the risk presented by each current or proposed relationship (taking into account factors such as the nature of the services to be provided and the corruption risks associated with the jurisdiction where the Subject is located).

We tailor the scope of our work to our client’s specific requirements; however, the most common scope chosen by our clients would typically seek to identify information on:

• The identity of the company.
• Its business background and activities.
• Its ownership (including indications of state ownership).
• Any political or official connections held by the Subject or its Principals.
• The reported involvement of the Subject or its Principals in a pre-agreed set of ‘noteworthy’ issues (including bribery and corruption).
• Searches of a range of pre-agreed international sanctions lists and PEP databases.

Forensic Risk Advisory

Fraud prevention is crucial. Once fraud or misconduct is reported the strongest of reputations, however long established, can be impacted very quickly.

At Deloitte, we draw on years of experience of working with clients across a wide range of industries and multiple jurisdictions. We provide proactive help and support alongside in-depth analysis that quickly identifies any vulnerabilities, developing powerful fraud response strategies that keep your organisation protected. Once these strategies are in place, we continue to monitor the ever-changing regulatory and economic landscape to identify new and emerging fraud risks and take the appropriate actions.

Our team of financial crime specialists combine extensive knowledge and skills with a proven methodology. Developed and evolved over years of experience, this represents a comprehensive, structured approach to developing your fraud risk management framework.

Fraud Risk Framework Review

A review of your organisation’s policies and procedures, alongside discussions and interviews with a cross-section of your staff. This helps us to assess the effectiveness of your existing risk management system and to design and implement the remediation activities you may need.

• Fraud Risk Assessment workshops: These interactive sessions with both staff and management allow us to identify and prioritise the diverse risks facing your organisation.
• Cultural Assessment: We use a survey tool to gain insight into your organisation’s ethical culture by investigating employee perceptions of key facts that might contribute to, or mitigate, your organisation’s vulnerabilities. We then provide management with a detailed analysis of employee understanding and awareness of all the issues surrounding fraud and misconduct. 
• Fraud Monitoring and Detection: Using data analytic tools, we analyse large volumes of data, allowing us to identify potential financial crime activity within your organisation. Data analytics are also a vital element of our risk assessment and target compliance processes.

M&A Integrity Due Diligence

M&A Integrity Due Diligence (“M&A IDD”) is the gathering of independent information to gain an understanding of – amongst other factors– a target’s background, track record and reputation, as well as any integrity or corruption risks. Now an established element of good corporate governance and part of the overall due diligence process, M&A IDD rarely results in “deal breakers”. Typically, it identifies risks that can be effectively mitigated either pre- or post-completion.

Gathering information through a combination of public record research and enquiries within the relevant jurisdiction, we focus on identifying issues of relevance to our clients. These typically include:

• The background, track record and professional reputation of the target and key management.
• The beneficial ownership of the target (including any hidden beneficial owners or influencers)
• The political and government links held by the target and key management, and their impact on the target’s activities
• The involvement of the target and key management in ‘red flag’ issues such as corruption, bribery, fraud, terrorist financing, money laundering and organised crime
  

Investigation Readiness

In essence, Investigation Readiness is built upon a “current state assessment” of your organisation’s approach to managing financial crime risk, including your policies and procedures, and your approach to third party due diligence and data analysis.

How can we help?

• Training – developing internal training for clients on (for example) ABC policies and procedures, fraud awareness and whistle-blowing procedures.
• Corruption Analytics – a cross-service line initiative with Forensic Analytics and Audit Advisory designed to deliver leading edge corruption “red flag” data analysis.
• Corporate Investigation call-off contracts – cementing our relationship with corporate clients through establishing, the parameters and terms on which Deloitte Forensic would be engaged to deal with relevant investigation issues, should they arise.

Sanctions

Achieving compliance is a complex process. Regulations frequently vary across separate jurisdictions and their requirements change constantly. Only limited guidance is available from the regulators and authorities themselves.

Deloitte has unparalleled experience in this area, having designed, reviewed, enhanced, implemented and monitored numerous financial sanctions detection and compliance programs for clients around the world. The team has established strong relationships with key relevant regulatory authorities and advised financial and non-financial institutions on a wide range of sanctions compliance matters.

Our work has included assessing sanctions risk at the enterprise and business unit level, drafting and enhancing policies and procedures, creating and delivering training modules, compliance assessments, retrospective "look back" investigations following regulatory orders, internal controls assessments, selection and implementation of technology solutions, internal investigations and the creation of enterprise-wide private sector Financial Intelligence Units (FIUs).  

Anti-Money Laundering

Anti-money laundering is part of our unique financial crime offering. We have extensive experience in leveraging our global anti-money laundering team to provide tailored solutions to many leading financial institutions as well as smaller organisations.

We offer advisory services across the entire lifecycle of AML compliance, drawing on the breadth and depth of our AML capability to provide a comprehensive, tailored service. We regularly work with Financial Crime and Compliance departments whose concerns with AML overlap with issues related to Trade and Economic Sanctions, Fraud, Bribery and Corruption.

Our services include:

• Policy & Procedures Benchmarking – finding a model which meets regulatory requirements and is aligned to the firm’s risk appetite.
• Risk Assessment – detailed consideration of the key risks factors and the impact on mitigation plans and controls.
• System Optimisation – including specification/selection of transaction monitoring systems, CDD systems and fine-tuning of these in operation.
• CDD & SAR Retrospective Reviews – including clearing backlogs, “refresh and/or remediation projects”.
• Training – both input to firm-wide training and in-depth sessions for dedicated professionals.
• Compliance Reviews – identification of how well a firm is meeting regulatory requirements, including mock ARROW visits, support during or before s.166 reviews and preparing and supporting the firm for every eventuality.