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T: +971 43723 000 | F: +971 43723 001
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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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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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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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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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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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 [email protected]