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.