Anti-Corruption Compliance Services

Why it’s time to revisit your anti-corruption program

• Implementation of new Department of Justice (DOJ) Pilot Program to motivate companies to voluntarily self-disclose Foreign Corrupt Practices Act (FCPA)-related misconduct and remediate flaws in their controls and compliance programs.
• Appointment of DOJ “Compliance Counsel” to provide expert guidance to prosecutors evaluating the compliance programs of companies under FCPA investigation.
• Increased global anti-corruption enforcement, especially in the UK and the Netherlands, that has led to numerous large corporate and individual prosecutions and which may pose risks to US-based multinational companies operating in those jurisdictions.
• The announcement of more stringent global anti-corruption initiatives in numerous countries, including France and Mexico, that may provide greater protection for corporate whistleblowers and dedicate more resources to combatting corruption.
  
• Increased accountability of individual corporate officers one year after the DOJ’s issuance of the “Yates Memo,” outlining parameters within which companies might receive “cooperation credit.”
  
• The hiring of additional dedicated resources by the DOJ, Federal Bureau of Investigation (FBI), and other global regulators specifically for investigating and combatting bribery and corruption.
  
• Increased global M&A activity, particularly in high-risk markets where the application of “successor liability” principles by authorities may lead to increased corruption-related risks.
  

In response to these and other activities, many legal and compliance officers are revisiting their compliance programs to assess whether they effectively deter, prevent, identify, respond to, and mitigate corruption-related risks. How effectively can your compliance program withstand government scrutiny? Deloitte can help.

Don’t settle for less than a knowledgeable, experienced advisor

Our Anti-corruption Consulting practice assists companies in designing, implementing, and assessing anti-corruption compliance programs, as well as conducting global corruption investigations when warranted. Our deeply experienced team of dedicated forensic professionals in the US and throughout Deloitte’s global network—in alignment with Deloitte’s eDiscovery, Analytics, and Business Intelligence resources—can help your organization align its anticorruption compliance efforts with your corporate objectives and risk appetite.

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Core services

With more than 20 years of anti-corruption experience, our specialists provide clients with a variety of proactive and reactive anti-corruption compliance services, including:

Compliance program assessments and “health checks”: Assessing the design and effectiveness of existing anti-corruption compliance programs, including the review of third parties as allowed by third party contracts.

Compliance program development and enhancement: Establishing new or refining existing compliance programs with a focus on mitigating potential corruption risks, both proactively (risk assessments) and reactively (investigative findings).

Merger and acquisition due diligence: In acquisitions, focusing on identifying potential corruption issues and risks of successor liability, and in divestitures, assessing anti-corruption compliance and identifying potential issues that may arise during due diligence.

Internal forensic investigations: Investigating corruption allegations and using forensic resources, technology tools, and subject matter specialists to enhance the efficiency of the investigative process.

Third-party forensic assessments and investigations: Assisting in exercising companies’ audit rights to review and assess certain third-party relationships, whether as part of a normal audit cycle or to investigate specific allegations of potential corruption-related misconduct.

Third-party due diligence: Performing background investigations of individuals and business entities in various investigative contexts leveraging our proprietary analytics platform to gather and risk-rank third-party data and manage the investigative background research performed on those third parties.

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Why so many companies rely on Deloitte

Our Anti-Corruption Consulting team is one of the largest, most experienced, and globally well-positioned groups in the industry. It includes senior leadership professionals from government agencies who provide direct, firsthand knowledge of current regulatory trends and expectations, as well as extensive forensic resources in key markets around the world. We offer:

• A US-based team of more than 700 forensic professionals, many with specific experience in anti-corruption programs and investigations.
• Firsthand knowledge of US regulatory trends and expectations: One recent addition to our team is Matt Queler, former Assistant Chief of the DOJ’s FCPA Unit, who directly led and supervised some of the most complex FCPA matters with seasoned professionals including a former Assistant Chief of the DOJ’s FCPA Unit.
  
• Significant global reach and in-country resources: Through the Deloitte Touche Tohmatsu Limited (DTTL) network of member firms, we can access more than 3,000 forensic professionals in over 145 countries with local language capabilities and knowledge of the regulatory environments, business customs, and practices in their respective countries.
  
• Quick, efficient mobilization of global investigative response teams: We can scale and quickly deploy teams in multiple countries simultaneously to help companies address compliance risks, enhance credibility, drive efficiencies, and contain investigative costs.
  
• Advanced, cost-saving data discovery and analytics capabilities, including a full suite of solutions to assist with data preservation, collection, processing, hosting, and analysis and employing advanced analytics and reporting solutions that summarize and analyze large, complex sets of both structured and unstructured data.
  
• Broad-based business intelligence resources for performing background investigations of entities and individuals, virtually anywhere in the world, including searches into potential conflicts of interest, undisclosed business affiliations, potential government affiliations, and adverse media reports.
  

Learn more about why so many businesses around the world rely on Deloitte for guidance on and support with their anti-corruption compliance programs and activities.

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