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January 2017CONFIDENTIAL

Task no: ACFE

BENEFITS OF CONDUCTING RISK

ASSESSMENTS TO MANAGE BRIBERY

AND CORRUPTION

ACFE MIDDLE EAST CONFERENCE

Kanupriya Jain

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1

This presentation is made by Kanupriya Jain of Control Risks and may contain sensitive and/or confidential

information relating to work she has undertaken. Control Risks requests the participants to respect the confidentiality

of any information shared and they should avoid sharing information discussed or any content shared during the

session with anyone outside the ACFE conference session.

Confidentiality

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Introductions

Compliance / Legal?

Risk management / Investigations?

Internal audit?

Others?

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Today’s session:

- Economic highlights of the Gulf

- History of bribery and corruption in the region

- Introduction to conducting risk assessments

- How? What? and Why?

- Case study

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The Gulf in the last 8 years

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2008–2009: Despite the real estate slump, the Gulf was rising!

What Next?

The rise of the

Gulf

Managing massive

wealth

The job crisis…

Waking from its

sleep

The Arab world

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Task no: ACFE

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2010–2014: economic uncertainty and the risk of war... Oh! It’s all about oil.

New dangers of

the world

economy

Please not

again…

The threat of ME war

Sheikh Vs Shale

The new

economics of oil

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2015–2016: change in world focus…

Saudi ArabiaThe regime’s blueprint

for survival

How to manage

migrant crisisAnd keep Europe from

tearing itself apart

Making Africa

work

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2015–2016: change in world focus…

The road to

BrexitTrump’s triumph

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New corruption laws adopted globally in 2016…

Tough anti-corruption law takes effect in South Korea

Brazil’s new anti-

corruption law

10 points on new anti-corruption rules cleared by PM Narendra

Modi

Firms face new anti-corruption law in

Mexico

Argentina proposes new anti-corruption laws

New French anti-corruption law: Companies doing business

in France must beware

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Task no: ACFE

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History of bribery and corruption in the region

Feb 16: Sweett Group to pay

£2.25m over Middle East

bribery

Nov 16: Suspected bribe by

KSA and Qatar paid to

Clinton while Hillary was

Secretary of State

Oct 16: Saudi Aramco’s ex-

employee accepted $1.7m

from Embraer for a $93m

deal

Mar 16: Global Unaoil

bribery scandal and a bribe

in Libya reported by a

whistle-blower in Oct 16.

May 16: Six senior Israeli

Power Company officials

indicted for taking bribes

from Siemens

Dec 16: Former Sweett

Group exec jailed for

destroying bribery evidence -

Sep 16: Och-Ziff Capital

Management to pay $412m

and CEO Daniel Och to pay

$2.17m for role in bribing

officials in several

African countries

Apr 16: Petrofac exec "paid

$2m bribe" to secure Kuwait

oil contract

Apr 16: Abu Dhabi Criminal

Court sentenced an oil firm

manager after he was found

guilty of taking a bribe of

AED150,000 from an

equipment supply

company

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Task no: ACFE

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Risk assessments – the What? Why? and How?

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Factors affecting an organisation

Policies

Operational procedures

Transactions

Employees

Government policies

Local

Regulations

International

regulations

People

ERP systems

Vendors

Customers

Senior

management Internal process

controls

Business

partners

Business goals

INTERNAL FACTORS

EXTERNAL FACTORS

Geo-political

situation

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Risk assessment approach

A risk assessment is a risk-based review of an organisation’s business. It helps to identify

corruption and fraud risks, gaps in risk mitigation, and can help control revenue leakages.

We explain two approaches to conducting a risk assessment in this session. These are:

Top-down approach

Bottom-up approach

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Task no: ACFE

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Top-down approach

Country risk profile

and laws

Tone from the top

Compliance

framework

Compliance

Procedures

Education and

training

Monitoring and

reporting

Raise the green card if you know all your company’s

policies relating to ABC risks.

Are you aware of all the risks that your organisation faces

while operating in the MENA region?

Are you aware if the policies have been approved by the

Board or management team?

Are you aware whether your company’s policies are

robust and provide you with adequate guidance to deal

with an ABC-related situation?

Does your organisation have a whistleblowing

mechanism?

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Bottom-up approach

Have you reviewed the financial transactions to

identify potential transactions that could be linked to

bribery and corruption?

Are you aware of the books and records clause of

the U.S. FCPA?

Have you undergone any specific ABC training?

Data analytics

and transaction

review

Identify key risks

and

vulnerabilities

Policy and

procedure for

each department

Compliance

framework

Tone from

the top

Targeted

training

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What is an appropriate risk assessment?

The stage of risk assessment

Maturity level of the organisation

Number of employeesBreadth of the jurisdictional spread

Existing internal and external audit

functions

Business sector

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Task no: ACFE

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Case studies

The session will include a walkthrough of two case studies for top-down approach and bottom-up approach that are not included in this deck due to confidentiality reasons.

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Questions?

In case of any questions, please write to kanupriya.jain@controlrisks.com