Day: July 1, 2020

This guide, published by Grant Thornton takes as its starting point that organisation need to be more proactive in identifying and combating fraud that may affect them.  It is intended to provide practical guidance for organisations looking to begin, advance, or benchmark their fraud risk management (FRM) programmes against industry best practices. It seeks to clarify and operationalise the concepts put forward in that guidance. As such, this playbook includes key questions, checklists, and insights that will enhance your FRM programme and ultimately facilitate proactive FRM at an organisation. It follows, and refers to the Fraud Risk Management Guide published in 2016 by the Association of Certified Fraud Examiners and the Committee of Sponsoring Organizations of the Treadway Commission. The “playbook” includes 10 “plays”, which are organised into 5 phases based on the 5 key FRM principles in the 2016 Guide –

• Fraud Risk Governance;
• Fraud Risk Assessment;
• Fraud Control Activities;
• Fraud Investigation and Corrective Action; and
• Fraud Risk Management Monitoring Activities.

It also includes additional information, templates, and tools that you can use to implement the 10 plays.

https://www.grantthornton.com/services/advisory-services/risk-advisory-services/ACFE-global-fraudcon-and-playbook.aspx

See also the slightly similar “Anti-Fraud Playbook”, produced in 2018 by the US Chief financial Officers Council –

https://www.cfo.gov/wp-content/uploads/2018/10/Interactive-Treasury-Playbook.pdf

 

 

 

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An article in Real Clear Defense on 1 July carried a Washington Post story that said that there are 53,000 US contractors were in the Middle East last year, compared with 35,000 US troops, according to a useful, comprehensive, timely and fascinating study by Brown University. Since 2001, an estimated 8,000 contractors for US companies have died on duty in the Middle East – 1,000 more than the number of US troops who have been killed. The article also notes that many of the contractors killed were foreign nationals and this has led to a double exploitation of using foreign workers for dangerous jobs and paying them less than US employees earn. It also provides a useful counterweight to concern and reports on Russian use of PMC, such as the Wagner Group.

https://www.realcleardefense.com/2020/07/01/military_contractors_shroud_true_costs_of_war_study_314244.html

https://www.washingtonpost.com/national-security/2020/06/30/military-contractor-study/

The full study is available at –

https://watson.brown.edu/costsofwar/files/cow/imce/papers/2020/Peltier%202020%20-%20Growth%20of%20Camo%20Economy%20-%20June%2030%202020%20-%20FINAL.pdf

 

 

 

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On 29 June, Blake, Cassels & Graydon LLP published an article comprising a primer which provides an overview of key requirements under Canadian sanctions legislation as of 30 June.

https://www.blakes.com/Insights/Bulletins/2020/A-Primer-on-Canadian-Sanctions-Legislation

 

 

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On 1 July, Sahara Reporters reported that a top Dutch diplomat, Hans Smaling, has been sacked from his position after comments about alleged unethical conduct and corruption indulged in by the country’s businesses operating in Nigeria.  He was stationed in Nigeria between 2015 and 2018.  He is quoted as saying that it was impossible to advance Dutch businesses in Nigeria without making dirty hands.

http://saharareporters.com/2020/07/01/diplomat-sacked-exposing-how-dutch-government-companies-engage-corruption-nigeria

 

 

 

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On 1 July, the European Sanctions Blog reported on a Court of Appeal case, with an appeal being dismissed and it being held that the defendant was “complying” with US secondary sanctions by not paying interest to the claimant, and that secondary sanctions were a mandatory provision of law under the agreement involved, because a “mandatory provision” did not only refer to a prohibition that directly bound the borrower not to pay. US secondary sanctions were an “effective prohibition”, and the reason for non-payment (which was what the Court said mattered) was to comply with them.

https://www.europeansanctions.com/2020/07/court-of-appeal-finds-us-secondary-sanctions-are-a-mandatory-provision-of-law-in-uk-contract/

 

 

 

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On 1 July, OFAC issued an Advisory on risks for businesses with potential exposure in their supply chain to entities engaged in human rights abuses in the Xinjiang Uyghur Autonomous Region (Xinjiang). Businesses with potential exposure in their supply chain to Xinjiang or to facilities outside Xinjiang that use labour or goods from Xinjiang should be aware of the reputational, economic, and legal risks of involvement with entities that engage in human rights abuses, including but not limited to forced laboUr in the manufacture of goods intended for domestic and international distribution.

https://content.govdelivery.com/accounts/USTREAS/bulletins/2938ddd

https://www.treasury.gov/resource-center/sanctions/Programs/Documents/20200701_xinjiang_advisory.pdf

 

 

 

 

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Another post on the FCPA Blog on 1 July advised that Aaron Ingenieros Constructores & Consultores EIRL., is ineligible to participate in World Bank-financed projects during the 15-month debarment. The post notes that World Bank debarment also applies to the Asian Development Bank, the European Bank for Reconstruction and Development, the Inter-American Development Bank, and the African Development Bank.

https://fcpablog.com/2020/07/01/world-bank-debars-two-companies-including-south-korean-firm-for-vanuatu-airport-fraud/

 

 

 

 

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On 1 July, the always useful FCPA Blog reported that Seoul-based Yooshin Engineering Corporation is ineligible to participate in World Bank-financed projects during the 13-month debarment. The debarment is related to the $60 million World Bank-funded Vanuatu Aviation Investment Project. The post notes that World Bank debarment also applies to the Asian Development Bank, the European Bank for Reconstruction and Development, the Inter-American Development Bank, and the African Development Bank.

https://fcpablog.com/2020/07/01/world-bank-debars-two-companies-including-south-korean-firm-for-vanuatu-airport-fraud/

 

 

 

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An article in Insight Crime on 30 June says that an index looking at the ability of Latin American countries to combat corruption has highlighted that signs of progress are still few and far between, and the region as a whole is backsliding. It finds that, in 2019, many countries in the region have moved away from anti-corruption measures. And the timing could not be worse, since corruption and graft have held back Latin America’s pandemic response in myriad ways. The countries are categorised as –

·      Above Average: Uruguay, Chile, Costa Rica;

·      Progress Needed: Brazil, Peru, Argentina, Colombia

·      Below Average: Mexico, Ecuador, Panama

·      Poor Performers: Guatemala, Paraguay, Dominican Republic             and Bolivia; and

·      The Outlier: Venezuela.

https://www.insightcrime.org/news/analysis/latin-america-corruption-index-worsening/

The report is at –

https://www.as-coa.org/sites/default/files/archive/2020_CCC_Report.pdf

 

 

 

 

 

 

 

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Kenneth Rijock, in his blog, has provided the above infographic.

https://rijock.blogspot.com/2020/07/alex-saab-moran-graphic-gold-for-food.html

 

 

 

 

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