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Corruption & Integrity: Enforcement and Investigation Trends

Rachel Coyle MBE, Tom Crooke 6 August 2019
6 August 2019    Rachel Coyle MBE, Tom Crooke

Emerging markets have always offered both opportunity and risk, but recent enforcement actions by US and EU regulators, in support of anti-corruption legislation, clearly demonstrate the need for vigilance as companies explore new jurisdictions.

In our latest report on corruption and integrity trends, we highlight some key themes brought out by recent enforcement actions by US and EU regulators, and how companies should react.

We also examine the UK’s Serious Fraud Office (SFO)’s capabilities following several high-profile failed efforts at prosecution, and take an in-depth look at Brazil’s long-running corruption saga, Operation Car Wash.


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It’s clear that the Foreign Corrupt Practices Act and UK Bribery Act have shaped the way many organisations think about compliance and integrity risk. Recently we have seen some international operators reduce their reliance on commission-based networks of third-party introducers, as it becomes apparent that this way of doing business significantly increases a company’s risk exposure. US regulatory agencies have been particularly vigorous in their pursuit of companies and alleged corrupt practices, bringing charges against non-US companies and individuals for actions not carried out on US soil, underscoring the importance of FCPA compliance.

At S-RM we support clients in building their resilience to risk, and managing their exposure to financial crime, corruption and commercial disputes. We always ask our clients: do you really know who you’re dealing with? Are there any hidden stakeholders? Have they been investigated for improper business activities in the past?

We enable our clients to better understand bribery and corruption concerns, and the track record and political exposure of the individuals they are dealing with, and ultimately make well-informed decisions that balance opportunities and risks.

To request a proposal, please speak to one of our experts.

Tom Crooke
Tom crooke Associate Director Email Tom
Rachel Coyle MBE
Rachel coyle mbe Head of Corporate Intelligence Email Rachel

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