What is GMETH Risk and Why is it Important?


What is GMETH Risk and Why is it Important



 You can download a full copy of the slides from this webinar. 




Full transcript available below:

Hello everyone and welcome to todays webinar, hosted by me Joe Boyhan and John Kearney of MyComplianceOffice and compliance expert Michael Volkov. 

Well thank you Joe. Thank you My Compliance Office, for sponsoring this webinar. I appreciate it. I think this is an important topic to sort of return to, because this to me, is an example of gifts, meals and entertainment and hospitality risk, is an example of where automation and other techniques, and data analytics for example, are definitely moving the compliance ball. I want to sort of focus on that as much as we can.


First I think the way to look at gifts, meals, entertainment, and travel, and hospitality risks, is this is a potential way that money can be taken out of the company and used for improper purposes. We've got to have tight controls around how well this money is going to be used, how this money is going to be authorized, and how we're going to document and be able to audit, real time as much as possible, these expenses. Because what we've seen, and we'll talk about this a little bit more, is what I see as a real risk in terms of funding bribery schemes. It's an easy way for people to get money, and it's an easy way for people to abuse the proper uses of money. And if there's anything that the SEC and the Justice Department want to see, is strong controls around this high risk factor, particularly in certain countries, which we'll talk about.


We know they can fund bribery schemes. We've seen weak controls cited in numerous enforcement action. Sometimes this funding source has been the sole source for bribery payments, and sometimes it's another source that's used to sort of add to other bribery payments. It's definitely a way that is a high risk area and we need to take a look at. Now, what are some of the areas that we want to focus on? What are the areas where we don't want to see ourselves engaging in certain practices, or what I would call weaknesses? One is, look, a lot of people right now use Concur, and then they take the Concur system and then they add a field for G, for government officials. But that is sort of antiquated. That's not the way that the sort of best technology and best practices that are out there are going to sort of dictate a much better, a much more robust process.


One is we've got to make sure we identify who our foreign government recipients are, particularly for health care professionals or obviously officials in a state-owned enterprise, in an oil and gas company or whatever. We want to have the ability to monitor the recipients so that we know why they're getting gifts, how many times they're getting gifts, who our people are meeting with and what's the purpose of the meeting, or the purpose of the dinner, or the purpose of whatever hospitality event is scheduled. We want to make sure that these controls apply with regard to third parties as well. We have travel agents, for example, in China that are often used as a way to funnel money to them, and a way to sort of facilitate bribery payments, and a way for an employee who wants to engage in improper activities to enlist the support of the corrupt travel agent.

 That's sort of an outline of what we're looking at in general, in terms of the risk. 


This webinar was co-hosted with Michael Volkov of VolkovLaw.


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