MyComplianceOffice Blog

Many organizations look to auditors as their primary source of fraud detection. That’s a mistake according to the Association of Certified Fraud Examiners (ACFE). In 2018, an ACFE study found 53 percent of occupational fraud is identified by employees other than auditors. That’s compared  to just 15 percent detected by internal auditors and just 4 percent by external auditors.   

The UK Bribery Act was implemented nearly eight years ago, but no case law exists to offer organizations an interpretation of corporate hospitality rules. The sole source of guidance to date has been from the Ministry of Justice in 2011.  

Earlier this year, the National Futures Association (NFA) put forth guidance to commodity pool operators (CPOs) on the regulator’s Compliance Rule 2-9 that took effect on April 1. The guidance (aka “the Notice”) applies to CPOs with control over customer funds. It outlines what CPOS should be doing to manage employees and how they should be supervising third parties in order to meet their obligations under the new rule focused on internal controls.  

There’s not much available from UK regulators on what they expect from an overarching corporate compliance program. Most guidance issued to date has focused on prescriptive compliance with specific regulations. But UK corporations can look to the U.S. Department of Justice (DOJ) for a solid program template. 

Chances are your organization has developed a conflict of interest (COI) policy. But does it have an effective COI compliance program in place? Can you demonstrate it to regulators? If the answer is no to either of those questions, there are three things you need to do now to satisfy regulators that you take COI prevention seriously.