One of the more prescient authors I know is Ryan C. Hubbs, a senior manager of fraud investigation and dispute services at Ernst & Young LLP (EY), who, in 2014, wrote an article for Fraud Magazine entitled “Shell Games”. In this piece, Hubbs wrote about how criminals use shell corporations to launder money and perpetuate frauds such as violations of the Foreign Corrupt Practices Act (FCPA). He explained what shell companies are and how certified fraud examiners could assist companies in internal investigations around these issues. His prescience was foretelling the information that would begin to become available with the release of the Panama Papers. Today I will begin a two-part series, where I describe some of the issues raised by Hubbs back in 2014, reporting on information in the Panama Papers and what you can do with the detect prong of your compliance program.
‘Enforcement 40’ for 2020
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