Anti-Corruption Informational Series teleconference – 18 June 2014, Delhi
The Anti-Corruption Informational Series Teleconference was conducted on the 18th of June. Mr. Arpinder Singh (E&Y-National leader of Fraud, Investigation and Dispute) spoke about the “FCPA Investigation Lifecycle”.
The various points covered in the teleconference were:
1. EY Global Fraud Survey- 2014: The survey established the importance of having Whistleblower Hotlines as most tips are received through the same. The survey further established that the enforcement of anti-bribery and anti-corruption compliance (i.e. penalties for breach of anti-bribery and anti-corruption policies, participation of the management in training and corruption risk assessment) has reduced since 2012.
2. FCPA Investigation Lifecycle
i. Stage 1: Identification of breach of FCPA through internal (whistleblowing complaints, internal audits/assessments,) or external channels (whistleblowing complaints to authorities, industry/country sweeps).
ii. Stage 2: Collection and preservation of information.
iii. Stage 3: Investigation Compliance Program
iv. Stage 4: Conclusion (production of records/information, settlements, penalties etc.)
v. Stage 5: Remediation through revision of internal control/procedure, a monitoring plan and establishment of an anti-bribery and anti-corruption framework.