FCPA Blog Tour Bogota V3 - Mayer Brown Investigations 16 Oil and Oil-Services Industry – Panalpina...

High-VelocityEnforcement

DOJ / SEC Matters Initiated | 2002 - 2010

Total Criminal and Civil PenaltiesImposed on Corporations | 2002 - 2010

WhatHas NotChanged?

Photo © Edgar de Evia

WhatHasChanged?

Total Criminal and Civil PenaltiesImposed on Corporations | 2002 - 2010

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Overview

1. Current Enforcement Picture

2. Legal Elements of the Offense

3. UK Bribery Act Effective Date

4. Designing and Implementinga Compliance Program

5. Third Party Agents and Due Diligence

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CurrentEnforcementPicture

FCPA Global Enforcement Trends

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• Corporate mega fines fueled by voluntary disclosureprocess.

• DOJ has dedicated additional prosecutors to FCPAcases.

• FBI has dedicated FCPA squad.

• Obama administration is continuing focus on FCPAprosecutions.

• FBI is using aggressive investigative tactics.

• DOJ is increasing use of industry-wide investigations.

FCPA Enforcement in Latin and Central America

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• US Department of Justice is increasing prosecution ofnon-US corporations and individuals in United StatesCourts.

• In 2010, 70 percent of the companies prosecuted forcriminal FCPA violations were foreign companies

• Many of the criminal cases involve corruption in Latinand Central America, particularly Brazil, Mexico,Venezuela, and Argentina.

• US Department of Justice is increasing coordinationwith Latin and Central America enforcement agencies

Increase in FCPA Enforcement Actions

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2

7 7

1820

26

48

35

8

20

13 14

26

0

10

20

30

40

50

60

2004 2005 2006 2007 2008 2009 2010

DOJ

SEC

2010 witnessed an 85% increase in FCPA enforcement actions over 2009, which itself was a record year.

Blockbuster FCPA Settlements

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$579

KBR/Halliburton

2010

2009

2008

$0

$100

$200

$300

$400

$500

$600

$700

$800

$900

$800

Siemens

ENI/Snamprogetti

$400 $365 $338

$185$137

$82 $58 $52

BAE Systems

Pride International

Technip

DaimlerAlcatel-Lucent

PanalpinaABB

2010 Total*:2010 Total*:$1617$1617

* Eight of the top ten monetary settlements in FCPA history were reached in 2010.

0 10 20 30 40 50 60 70 80 90 100

84 months84 monthsAlbert Jack Stanley,KBR

63 months63 monthsDouglas Murphy,American Rice, Inc.

57 months57 monthsJuan Diaz,Third party consultantto Haiti Telco

48 months48 monthsRobert Antoine,Haiti Telco

37 months37 monthsJohn Warwick,Ports EngineeringConsultants Corporation

37 months37 monthsDavid Kay,American Rice, Inc.

87 months87 monthsCharles Paul Edward Jumet,Ports EngineeringConsultants Corporation

Most Severe Jail Sentences for FCPA Violations

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Industry-Wide Investigations

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Oil and Oil-Services Industry – Panalpina Investigation – Vetco settled FCPAcase in 2007 based on illegal bribes made through Panalpina. Followingsettlement, DOJ issued at least 11 letters to oil and oil services companies,requesting information about their dealings with Panalpina. On Nov. 4, 2010,DOJ and the SEC announced settled FCPA enforcement actions against Panalpinaplus six of these oil and oil services firms (most of which were Panalpinacustomers) totaling $236.5 million in disgorgement, fines, and penalties.

Industry-Wide Investigations

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• Medical Device and Pharmaceutical Industry

1. E.g., Biomet, DePuy, Diagnostic Products, Medtronic, Micrus, Smith & Nephew,Stryker, Syncor, Wright Medical, Zimmer Holdings

2. E.g., Eli Lilly, Merck, Astra Zeneca, Bristol-Myers Squibb, GlaxoSmithKline,SciClone

• Military and Law Enforcement Products Industry

1. E.g., SHOT Show Sting targets, Armor Holdings, DynCorp, Smith & Wesson,Allied Defense, Blackwater/Xe

• Telecommunications Industry

− E.g., Alcatel-Lucent, Haiti Teleco, ITXC, Latin Node, Magyar Telekom, Siemens entities, UTStarcom, Veraz

SEC recently launched industry-wide investigation against global financial companiesfocusing on dealings with sovereign wealth funds

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Corruption in Latin America

Latin America Economic Trends

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• Countries in Latin America, such as Brazil, Mexico,Colombia, Peru, Chile and others, are attracting globalinvestment because of significant economicopportunities

• The region is viewed as attractive for foreigninvestment

• At the same time, governments are increasing anti-corruption and other enforcement programs to reducecorruption and anti-competitive activities.

Corruption Risks in Latin America

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CORRUPTION PERCEPTIONS INDEX 2009

Global Perception of Latin America Corruption

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• Transparency International has reported that 22 ofthe 32 countries in Latin America are perceived tosuffer from high levels of corruption

• This problem of corruption goes hand in hand withthe high level of inequity that has not beenovercome by the economic growth experienced bythe region in the last few years.

• Weak government institutions, low levels ofgovernance and the influence of particularinterests negatively affect efforts to promoteequitable and sustainable human development.

International Efforts to Reduce Corruption

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• Nearly all Organization of American States (OAS)member states have signed and ratified two key legalinstruments that provide a foundation for preventingcorruption: the Inter-American Convention againstCorruption and the UN Convention against Corruption.

• Most signatory countries have joined the follow-upmechanism of the Inter-American Convention, afundamental step for the treaty to become trulyeffective.

• Member states have generally been slow to implementmeaningful reforms and enforcement program

Level of Anti-Corruption Enforcement

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• Improvement of Anti-Corruption Laws Applicable toCompanies

• International pressure to reform laws to comply withinternational treaty obligations

• Slowly, countries have been increasing enforcementefforts with new tools provided by new laws

• Dissemination of Compliance Culture among Companies

• The Level of Enforcement is Likely to Increase, but at aSlow Pace

Elements of theOffense

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Designing and Implementing an Anti-corruption Compliance Program

• FCPA was first enacted in 1977 but it has acquired new vigorin the post-SOX environment.

• The FCPA consists of civil and criminal penalties

• The FCPA has two parts:

1. The anti-bribery provisions

2. The books and records/internal controls provisions (applies to"U.S. issuers")

FCPA Violations

Who is liable under the FCPA?

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Domestic

• All US “issuers” and private companies (“domestic concerns”)

• Any US corporation or national or any foreign bribery-related conduct

• US citizens or foreign nationals operating in the US or usinginstrumentalities

Foreign

• Foreign corporations subject to SEC regulation (e.g., via ADRs) and usinginstrumentalities

• All foreign persons when in US territory, whether or not they useinstrumentalities of interstate commerce

Includes directors, officers, employees, and agents of entitiessubject to the statute

Elements of an FCPA Violation

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Accounting /Recordkeeping Provisions:

Under the books andrecords provisions, issuersmust keep accurate booksand records and maintainadequate internal controls.

Anti-Bribery Provisions

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“It is a crime for any U.S. Person or Company to directly orindirectly pay or promise money or anything of value to anyforeign official to obtain or retain business or any otherimproper advantage.”

Money or Anything of Value

• Cash

• Gifts (such as expensive meals, wines, merchandizingwith the Company logo)

• Services

• Travel expenses

• Business Opportunities; Advantages; Changes in law.

• Bribe need not to be paid ― the promise of a bribe is also illegal.

• The terms “obtaining or retaining business” or any“improper advantage” are construed very broadly.

Foreign Official

• Government officials and employees

• Political party candidates and employees

• Employees of government controlled companies orinstrumentalities

• Employees of public international organizations

• Any others in an official capacity (including honorarypositions)

State Owned Enterprises

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• A “foreign official” includes any officer or employeeof a non-U.S. government, and any officer oremployee of “any department, agency, orinstrumentality” of a non-U.S. government.

• FCPA applies to interactions between businessesand state-owned companies owned by foreigngovernments (e.g. Ecopetrol in Colombia)

• To determine whether employees of a state-ownedenterprise are “foreign officials”, SEC and DOJconsider the percentage of government ownershipin the enterprise and the amount of control thenon-U.S. government exerts over the entity inquestion.

Knowledge and Intent

• It is unlawful to make a payment to any third partywhile “knowing” that all or a portion of such paymentwill go directly or indirectly to a foreign official.

• “Knowledge” is broader than “actual knowledge,” andincludes “conscious disregard” and “willful ignorance.”

• “Firm belief” that an illegal payment is “substantiallycertain to occur.”

• Any third party – Agents; consultants; contractors;representatives; partners in a joint venture; subsidiaries

1. KBR (2009)

Civil Penalties

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• In the civil context, the SEC and DOJ can impose a$10,000 fine per violation upon individuals andcompanies.

• The SEC may also impose further civil penalties rangingbetween $7,500 to $150,000 upon individuals and$75,000 to $725,000 upon companies.

• Alternatively, the SEC may impose a civil penalty equalto the gross pecuniary gain to an individual or companyand equitable relief, such as disgorgement of profits.

Criminal Penalties

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• For companies, criminal violations can result in:− $2 million fine for an anti-bribery violation; and− $25 million fine for a books and records violation.

• Individuals face up to:− 5 years in jail with a maximum $250,000 fine

for an anti-bribery violation; and− up to 20 years in jail with a maximum $5 million fine

for a books and records violation.

• Under a federal alternative fine provision, companies andindividuals may be fined up to twice the benefit sought orreceived.

Exceptions and Affirmative Defenses

• It is NOT a defense that “everyone else is doing it.”

• This, unfortunately, can give a sense of false security,but will provide absolutely no protection in the eventthe underlying activities are not in compliance.

• Use thoughtful common sense, and don’t be lulled intothinking it’s OK because “That’s the way XX does it” or“Its always been done that way here in XXX.”

Affirmative Defenses:

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Reasonable Bona Fide Marketing and PromotionPayments and Payments Authorized Under WrittenLanguage of the Foreign County

• Reasonable and bona fide expenditures, such as travel and lodgingexpenses directly related to (A) the promotion, demonstration, orexplanation of products or services, or (B) the execution or performanceof a contract with a foreign government or performances of a contractwith a foreign government or agency thereof.

• Travel expenses to United States (FCPA Op. Proc. Rel. 07-01)

• Product samples for testing (FCPA Op. Proc. Rel. 09-01)

• Journalist stipends (FCPA Op. Proc. Rel. 08-03)

• Trips to tourist destinations (US v. Metcalf & Eddy, Inc)

UTStarcom Incorporated (2009)

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• Arranged and paid employees of Chinese state-ownedtelecommunications companies to travel to populartourist destinations in the United States, includingHawaii, Las Vegas and New York City, and makingimproper payments to consultants in China andMongolia while knowing that they would be used topay bribes to foreign government officials.

• UTSI voluntarily disclosed the violations, and agreed topay a $1.5 million penalty to the DOJ, plus $1.5 millionto the SEC.

Exception:

• Facilitating or Expediting Payments

1. Small payments for the purpose of expediting or securing theperformance of a routine AND non-discretionary governmentalaction (something for which the Payor is already entitled).

2. Facilitating payments need to be properly recorded and identified assuch.

3. Facilitating payments are usually illegal under local laws.

4. Vetco Gray – average $5,550 (378 payments in 2 years = $2.1M)

• Current trend/Best practices: limit facilitating payments tolife threatening situations or eliminate completely.

Mergers and Acquisitions:Buying an FCPA Violation

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• Acquiring company can buy liability for FCPAviolations which occurred prior to the acquisitionunless the acquiring company conducts a “duediligence” review.

• Due diligence review will identify the past FCPAviolations and the target might need to make adisclosure to the Justice Department.

• Companies will have to address past FCPA violations:change in price, structure, additional warranties andindemnifications; deal could terminate or bedelayed.

• Similar procedure occurs in joint ventures.

UK Bribery Act:Effective this Year

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UK Bribery Act Basics

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• Two general offenses forbribing or taking a bribe

• A discrete offense ofbribing a foreign publicofficial

• A new corporate offensefor failure to preventbribery

UK Bribery Act:Corporation’s Failure to Prevent Bribery

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• Person associated with a commercial organization bribes another:

1. The term “associated persons” includes any person who “performs services for oron behalf of the relevant commercial organisation” – and may includesubsidiaries, employees, agents, JV partners, consortium members.

• Defense to liability if the commercial organization has “adequateprocedures” to prevent such bribery from occurring:

1. A “commercial organization” includes UK entities and thosecompanies and partnerships incorporated or formed overseas that “carry on abusiness or part of a business in the UK.”

• The bribery may occur anywhere in the world – a conviction forbribery in the local jurisdiction is not required.

UK Bribery Act: Delay in Implementation

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• UK Bribery Act effective date of April 2011 recently delayed forsecond time until guidance is issued (3-month lag betweenguidance and effective date).

• UK government is conducting “review” of law because of UKbusiness complaints.

• UK prosecutors have stated they intend to aggressively enforcethe Act against global companies “doing business” in UK.

• Guidance on “adequate procedures” defense and prosecutionpolicies are supposed to be issued three months before neweffective date.

FCPA & Bribery ActSimilarities:

FCPA v. Bribery Act: Comparison

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Covered:payment of money or anything of value;

Bribery Act: “financial or other advantage”

BroadlyApplied to:

third parties (agents, consultants and distributors)and have broad extraterritorial reach

Persons: bribery of foreign official public and private

Intent: “corrupt intent” “intention to influence”

Exceptions andDefenses:

facilitation exception for “greasepayment”, affirmative defenses forreasonable bona fide expenses or

legal under written local law.

corporate offense forfailing to prevent bribery;

affirmative defense:had “adequate procedures”

FCPA Bribery ActDistinctions:

The Risks ofFCPA and UK Bribery Act Enforcement Action

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• DOJ intends to increase “joint” enforcement actions; willcoordinate information sharing and enforcement actions.

• No company wants to be the “guinea pig” for initial UKBribery Act enforcement actions.

• Companies need to review and revise FCPA complianceprograms to address Bribery Act.

• Enforcement and interpretation of Bribery Act will be dynamicand require companies to keep up with requirements.

Designing andImplementing anAnti-CorruptionCompliance Program

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• FCPA Compliance Policy and Tone at the Top. The Companyshould develop and promulgate a clearly articulated andvisible corporate policy against violations of the FCPA and astrong commitment from senior management.

• Strong policy statement should be adopted by the Board.

• Board and senior management should be required to makecommitment to anti-corruption compliance.

• Compliance commitment must be demonstrated by actions.

Basic Elements of FCPA Compliance Program

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The Company should develop and promulgate compliancestandards and procedures which shall include policies governing:

a. gifts;

b. hospitality, entertainment, and expenses;

c. customer travel;

d. political contributions;

e. charitable donations and sponsorships;

f. facilitation payments; and

g. solicitation and extortion.

Anti-Corruption Policies and Procedures

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• The Company should develop its compliance standards andprocedures using a risk assessment.

• The risk assessment should be a formal and documentedreview which examines:

− the nature and extent of corruption in each country in which thecompany does business relying on public and internal sources ofinformation (Transparency International, OECD, etc);

− the extent of government interactions and the persons in thecompany responsible for such interactions; and

− the use of third-party agents, consultants in each country.

Use of Risk Assessment

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• Annual Review. The Company should review its anti-corruptioncompliance standards and procedures, on no less than anannual basis to ensure they are working.

• Ongoing Assessment. The Company should conduct ongoingassessments of its FCPA compliance program.

− During the year, Spot checks and quarterly audits of thecompliance program should be conducted.

− Dynamic process for modifying the compliance program should bemade as new information is learned.

Ongoing Assessment

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• The Company should assign responsibility to one or more seniorcorporate executives of the Company for the implementationand oversight of its Company's anti-corruption policies.

• Company should designate a compliance officer in seniormanagement and provide adequate resources to complianceoffice.

• Compliance officer should be separate from General Counseland internal auditing functions.

Senior Management Oversight and Reporting

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• The Company should ensure that it has a system of internal controlsfor the purpose of foreign bribery or concealing bribery.

• Internal controls are key to identifying and preventing bribery.

• Internal audits must be supplemented with forensic audits sinceinternal audits hinge on “materiality” and may not catch briberyschemes.

• Every expenditure of money where bribery may occur should havespecific controls and management procedures to prevent bribery (e.g.gifts and hospitality, review form for certain amounts and review bycompliance and legal offices).

Internal Controls

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• FCPA training which shall include: (a) training for all directors andofficers, and, where necessary and appropriate, employees, agents,and business partners; and (b) annual certifications, certifyingcompliance with the training requirements.

• Training programs should be tailored to different audiences and risks.Offices that have interactions (sales and regulatory) with foreignofficials should have different program from senior management.

• Legal and compliance staff throughout organization should haveseparate training program.

Training

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• The Company should establish or maintain an effective system for

a) Providing Guidance;

b) Internal Reporting; and

c) Response to such internal reporting.

• Internet-based guidance and reporting systems

• Hot-line reporting system for employees to make anonymous reports

• Detailed procedure for review and response to internetand hot-line reports

Ongoing Advice and Internal Reporting

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• The Company should have appropriate disciplinaryprocedures to address violations of the anti-corruption lawsand the Company's anti-corruption compliance code, policies,and procedures.

• Specific disciplinary procedure should be adopted foremployees who commit corruption offense.

• No tolerance policy should be adopted and enforced.

Discipline

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Foreign Business Representatives. The Company shall:

1) Perform appropriate due diligence on foreign business representatives;

2) Inform foreign business partners of its FCPA compliance program;

3) Seek reciprocal written anti-corruption and anti-bribery commitmentsfrom its foreign business partners.

Compliance Terms and Conditions. The Company should includeFCPA terms and conditions in its contracts with foreignbusiness partners.

Foreign Business

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Third Party Agentsand Due Diligence

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Due Diligence Screening of Third Party Agents

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• Screen the Initial Terms of Relationship with ThirdParty:

1. Review the creation of relationship, or any subsequent changes toresponsibilities or countries where agent operates.

2. Establish procedure for centralized review of contracts to ensureconsistent standards.

3. Depending on size of company, should establish review at highestlevel within the company.

• Develop a Different Screening Procedures for Review ofIndividual Transactions.

Guidelines for Due Diligence Process

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• Do not over-standardize procedure.1. Need to tailor to individual circumstances in each country based on

risk.

• Need to conduct background check to determine (5-10year history).

1. Existence of ties to foreign government officials and employees.2. Existence of any pending or prior investigations of bribery or other

criminal conduct or civil violations.

• Create written package and record of review andapproval process to demonstrate compliance.

Basic Issues to Cover

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• Existence of Relationships with Foreign GovernmentOfficials

1. Purchasing Authority2. Licensing or other regulatory authorities

• Prior History of Bribery and other Crimes

• Nature of Services, Compensation and PaymentMethod

• Written contract

1. Representations and warranties on compliance2. Right to inspect and audit third-party books3. Right to terminate contract if believe violation has or will occur

Red Flags

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Due diligence review of relationship or individualtransactions must include red flags which require additionalinvestigation before approval.

• Red flags are facts and circumstances that raise seriousquestions of an FCPA violation.

• Companies which ignore red flags run the risk of FCPAenforcement actions, criminal fines and the need for costlyremedial measures.

• A red flag only means that further scrutiny is warranted.

Red Flag Procedure

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• Red flags should be tailored to each country and therelevant risks.

• Red flags should be categorized based on risk factors(e.g. some are significant and require moreinvestigation than others).


A few thoughts - The perfect FCPA program

The settlement in late 2010 between RAE Industries and the Justice Department andSEC included a detailed outline of “best practices” for a forward-looking FCPAcompliance program.

Code of Conduct,Tone at the top,Anti-Corruption Policies and Procedures,Use of Risk Assessment,Annual Review,Oversight and Reporting,Internal Controls,Training,Ongoing Advice and Guidance,Discipline,Use of Agents and Business Partners,Contractual Terms And Conditions,Ongoing Assessment

Elements of a program that stands up to the Justice Department:

75% of the 1.8Billion related tofailure in the DueDiligence process


A few thoughts - The perfect FCPA program

Bullet point 11:

Exercise appropriate due diligence andimplement compliance requirements to ensureproper oversight of agents and businesspartners. These requirements should include:

performing risk-based due diligence for “thehiring and appropriate and regular oversightof agents and business partners”;

informing agents and business partners of the company’s commitment to follow thelaws against foreign bribery and of thestandards, procedures and other measuresthe company has in place to detect andprevent bribery; and

seeking a reciprocal commitment from agents and business partners.

Elements of a program that stands up to the Justice Department:

Bullet point 12:

Include standard provisions in agreements andcontracts with agents and business partnersthat are designed to prevent violations of theanti-corruption laws. These provisions mightinclude, depending on the circumstances:

anti-corruption representations and undertakings;

rights for the company to conduct audits of the books and records of the agent ofbusiness partner;

rights for the company to terminate its relationship with an agent or businesspartner as a result of any breach ofanticorruption laws.

Conduct periodic review and testing ofthetionship with an agent or businesspartner as a result of any breach ofanticorruption laws


“Existence of Relationships with Foreign Government Officials”-Gather the name of the owners/executives of the 3rd Parties-Compare against a reputable database of Foreign Officials –

Screening

“Prior History of Bribery and other Crimes”-On average Google finds 500 new articles on “corruptioninvestigation”-Company or Person with history of fraud or money launderingmay be a precursor to corruption risk

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How do you recognize a Red Flag?Definition: a flag that serves as a warning signal


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Who they are

Who “they” are – Identity Verification

• They – any agent, distributor, M & A

partner, client and vendor (TiPS)

• Verification confirms they are “who we thought they were”

• Works well in 10 Countries, other places…

• “Who they are” is just half the pie

William Kelleher - Reseller in IrelandCarraig na bhFearCork City, IrelandDOB 1/15/1972


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Who they aren’t…

Due diligence confirms

Who they aren’t - Negative Database

• 3rd Party is not affiliated with a foreign government, SOE, purchasingdecision for a government entity

• 3rd party is not being investigated for corruption (or fraud, or moneylaundering, etc.)

William Kelleher Billy KelleherPresident, XYZ FO Mstr. of State ,Trade and CommerceCarraig na bhFear 1st StreetCork City, Ireland Dublin, IrelandDOB 1/15/1960 DOB 1/20/1968

High RiskAgentsPartnersTIPs in high risk jurisdiction

MediumDistributorsResellers

Low RiskSuppliersVendors

Unsystematic Due DiligenceSystematic Due Diligence


• Take out the Garbage - Validate your information,gather critical data such as owners Details

• Knock down the silos – create a central database thatis consistent for all 3rd parties

• Screen – Prove who they aren’t, investigate

• Corruption happens every day, so should your duediligence

• Document, Document, Document

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Building Blocks of Systematic Due Diligence


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GIGO - “Check the Box” is not a sound policy

You can’t prove “who they aren’t” without the proper information:

WorldCompliance has 140 Foreign Officials or their contactscontaining “Juan and Ramirez”

Without a UI, Unique Identifier, you can waste valuable time andmoney proving who they are

Company: ABC CorporationLocation: Hong KongOwner: 唐老鸭

TLI – Too Little Information







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Deconflicting

• First Line of defense

• Important mechanism of controls

• Only part of your program that protects youcontinuously

Decentralized Vetting Process


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Deconflicting

• First Line of defense

• Important mechanism of controls

• Only part of your program that protects youcontinuously

Decentralized Vetting Process

?







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Who they aren’t

1 of a million documented foreign officials ortheir contacts

1 of tens of thousand of persons investigatedfor corruption

1 of thousands known corrupt foreign officials







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Carl Ahlgrimm – Mayor of small town in Germany –Appointed 2010

Nereu Alves De Moura – Member of Chamber ofDeputies, newly elected

Mohammed Abul-Enein – Chairman of Group Cleopatra,largest producer in the world of Ceramic Tiles, founded1983


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Due diligence is continuous


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Document your process and decisions

Stopped using XYZ Company in Romania as of March 3, 2011 for logistics as owner was brother of Mr.Teselena


Your Checklist should used to gather information, notchecking boxes

• Not a one time check

• There is no DOJ “anti corruption” certificate, yet

• Training is a component of your program, not theprogram

Is a process that is continuous, and covers all TiPs notjust the top of the pyramid

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Systematic Due Diligence

WorldCompliance

Metawatch License(Initial Due

Diligence/Investigations)• Manual Search• Multilingual Web Interface• Multilingual Name Matching

Zyng monitoring application(Ongoing Due Diligence)

•Enables continuous screeningof all relationships•Advanced Name Matchingintelligence•Advanced reporting

FCPAForce (Systematic DueDiligence)

•Wco verifies criticalinformation for client•No IT involvement•Wco deconflicts•Due diligence is completelyhandsfree

Solutions


Third Element of Third Party DueDiligence WorldCompliance

Luis Fernando Jamarillo


Third Element of Third Party DueDiligence WorldCompliance


Fourth Element of Third Party DueDiligence WorldCompliance

Designing and Implementing an Anti-corruption Compliance ProgramOngoing Due Diligence: periodicscanning of your businesscontactsWorld Compliance Global

Database GSL, GPL, GEL,GAL,GIL

Zyng NameMatching Tool

MatchReportbased onthefollowing:

•Name

•Dates ofBirth

•Passport/National IDNumber

•Country

Vendors/AgentsDistributors

Customers

M&APartners

WorldCompliance

Your database of currentrelationships


WorldCompliance

ZYNG MatchReport


WorldCompliance

Deciding who is a true matchor no match has never been

easier


Monitoring – risk profiles forrelationships change over time

World Compliance Global DatabaseGSL, GPL, GEL, GAL,GIL

Vendors/

Agents Employees

Customers Partners

Name MatchingReport

NameMatchi

ngSoftwar

e

Alerts


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• Gather and clean your information on your Tips

• Create central registration site for your company

• Screen against the largest database of FOS, bad guys

• Monitor your TiPS and alert you to new risk

• Create an audit trail that tracks all decisions, and documents

FCPA Force A New Solutions


Review

With the FCPA, the “long arm” of the US Justice System just gotlonger…..

Due diligence is the cornerstone of your Anti Corruption andAnti Fraud programs

WorldCompliance offers the largest database of ForeignOfficials, the largest and most comprehensive database of highrisk persons = the most protection

With FCPA Force, we can offer all 4 pieces to providing completeprotection for your organization in Latin Am and overseas

WorldCompliance

ContactRyan Morgan Pablo FerranteDirect: +1 305.579.2298 Ext. 262 Direct: +1-713-238-2662

[email protected] Cell: +1-713-240-5202

[email protected]

Richard L. [email protected] Bruno Werneck

Direct: +55-11-2504-4245

Michael Volkov Cell: +55-11-9104-1185Direct: (202) 263-3288 [email protected]

Cell: (240) 505-1992

[email protected]

FCPA Blog Tour Bogota V3 - Mayer Brown Investigations 16 Oil and Oil-Services Industry – Panalpina...

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