DOJ Fraud Section Puts Boards of Directors on Notice Regarding “Conduct at the Top”

In February 2017, the U.S. Department of Justice (DOJ) Fraud Section published its latest guidance on corporate compliance programs with the release of the very useful document titled “Evaluation of Corporate Compliance Programs.”

While many legal and compliance scholars have rightly stated that this latest publication isn’t anything radically different than prior authoritative guidance issued by the DOJ and other organizations, what jumps out is the reframing of the well-worn expression, “tone at the top,” with the potentially more insightful, and arguably much scarier, “conduct at the top.” In a just-released Flash Report, we put forth questions and insights that illustrate the degree to which the DOJ is examining senior management and the board of directors while evaluating a corporate compliance program.

Fraud Awareness Tip No. 5 – Make Sure Your Fraud Detection Tools Actually Detect Fraud

by Scott Moritz
Managing Director – Leader, Protiviti’s Fraud Risk Management Practice

In recognition of the 25th anniversary of the Association of Certified Fraud Examiners (ACFE) and International Fraud Awareness Week, Protiviti, whose practitioners include more than 100 members of the ACFE, is releasing a series of tips on fraud awareness to help raise awareness of the various ways that fraud can affect an organization and the proactive steps organizations can take to better position themselves in the ongoing fight against fraud.
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Enabling technologies can drive a lot of efficiencies across a wide array of compliance processes, including fraud detection. However, what steps should organizations take to determine if their systems have been properly configured? Is the company examining the right data and are a reasonable number of alerts resulting in actual investigations that lead to the prevention of fraud? Continue reading