Senior Management, Audit Committees and Regulators expect, if not require, fact-based and objective reporting on investigation findings, when a system or control override, or weakness, may have contributed to a suspected bribery event.
A Bribery Response Plan usually includes guidance on minimum requirements for investigation planning and mandating appropriate senior management oversight. Investigation findings may lead to a suspicious activity report ('SAR') being submitted to SOCA. In addition, findings will inform senior management consideration of whether a report should also be submitted to the Serious Fraud Office ('SFO').
Poor planning can contribute to evidence loss or damage, reputation risk and lead to regulatory and/or SFO concerns about a firm's anti-bribery culture:
When investigating suspected bribery:
FCRM conducts UK and international investigations, and we are accumstomed to working with clients and their professional advisers, when undertaking complex and/or confidential engagements.
On international assignments (where practicable) we use experienced investigators with knowledge of local language, culture and business practice
We deliver robust reviews and investigations, often in challenging circumstances. Reports include fact-based findings, objective commentary on internal systems and where required, practical recommendations to improve/enhance internal controls.