Risk Documentation The $18 Million USD Mistake

I am no longer amazed by the missteps of any financial organization. The incentive policies and amalgam of personnel with widely differing views (borne out of previous financial organizations) can lead to a cocktail of disasters. Today, policies and standards seem to be written in a vacuum, only to see the light of day when regulators call. However, it appears we do have a benchmark: a well-understood policy is worth $18 million, plus costs, time and energy.

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John Thackeray
5 Step framework for Effective Fraud Risk Management.

There are now more reasons than ever to implement an effective fraud risk management framework for personnel in your organization. The focus on individual responsibility has dramatically altered and employees should now be educated as to the risks and repercussions, especially in the U.S. As a result of the memorandum titled “Individual Accountability for Corporate Wrongdoing” issued by former U.S. Deputy Attorney General (DAG) Sally Yates on September 9, 2015 — even those who merely had knowledge that something wrong was happening but didn’t report it would potentially face penalties. Known simply as the “Yates Memo,” the directive signals the new priority in the U.S. Department of Justice’s (DOJ) pursuit of corporate wrongdoing — a priority of pursuing, punishing and deterring individual wrongdoers versus the corporation itself. According to the U.S. Security and Exchange Commission’s (SEC) annual report, issuer reporting and disclosure cases represented 20% of the SEC’s 2017 enforcement actions — the largest proportion in many years. 

What should an individual do when they suspect fraud or unethical behavior? Read on

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John ThackerayRisk Smart inc