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Bribery Schemes Part 2: Preventing Corruption in Your Sales Cycle


Compliance experts from Lextegrity, FRA, and Covington & Burling discuss how to proactively detect and prevent corruption in your company’s sales cycle.

According to Stanford Foreign Corrupt Practices Act Clearinghouse, 92% of the FCPA-related enforcement actions over the last 10 years were facilitated via third-party intermediaries in the customer revenue domain. 

These schemes involved distributors, resellers, and other sales agents. 

Bribery schemes that involve the sales cycle tend to be more complex and difficult to detect. Schemes often involve free-of-charge goods and services, unreasonably large discounts, and fraudulent credit notes provided to third parties that are used to create slush funds and facilitate bribery.

In this webinar, we cover:

  • checkmarkExamples of past FCPA violations involving sales schemes used to fund bribery
  • checkmarkExamples of transaction monitoring analytics that can spot abnormal behavior and curtail corruption and fraud schemes
  • checkmarkInternal controls that can proactively detect and prevent violations

The Expert Panelists:

Mihnea Rotariu Umair Nadeem Adam Studner

Mihnea Rotariu
Risk and Compliance
Analytics Director | Lextegrity

Umair Nadeem
Director | FRA

Adam Studner
Of Counsel | Covington
& Burling

Mihnea Rotariu has an extensive background in handling matters involving bribery and corruption, forensic accounting, monitorships, regulatory compliance, data analytics, and due diligence from his time at PwC and FRA. He holds several certifications, including Fellow of the Association of Chartered Certified Accountants (FCCA), Certified Fraud Examiner (CFE), and Certified Anti-Money Laundering Specialist (CAMS).

Umair Nadeem has over 15 years of forensic accounting experience and specializes in providing consulting and investigative services to private equity firms, external and in-house counsel, audit committees, company management, and government entities regarding issues of compliance and regulation, fraud and misconduct, regulatory enforcement actions, and the assessment of financial and legal risks relative to fraud and poor internal controls. He has extensive experience in assisting global organizations to develop and enhance corporate compliance programs, conducting cross-border investigations, and leading corporate monitorships involving allegations of bribery and corruption, potential violations of the US Foreign Corrupt Practices Act, financial statement fraud, embezzlement, asset misappropriation, and waste/abuse.

Adam M. Studner’s practice focuses on white collar criminal matters, internal corporate investigations, and compliance counseling. He regularly represents clients in Foreign Corrupt Practices Act (“FCPA”) and corruption-related internal investigations and risk assessments, designs and implements compliance programs, conducts transactional anti-corruption diligence, and responds to and defends against government investigations and prosecutions on behalf of both business entities across industries and individuals.

About Lextegrity

Lextegrity provides data analytics and automation technology for compliance and audit professionals to prevent and detect risks related to fraud, corruption, sanctions, kickbacks, and conflicts of interest.

Lextegrity’s software has been before regulators globally and was even cited by the SEC. It has been chosen after the appointment of compliance monitors or the start of investigations and has helped resolve those matters, including helping to secure a DOJ declination.

About FRA

Since 1999, FRA has worked all over the world to solve complex forensic issues for multinational clients. They are experts in forensic accounting, multi-jurisdictional investigations, corporate compliance monitorships, disputes and arbitration, data governance & forensics, complex data analytics, eDiscovery consulting, regulatory Disgorgement, Gain and Ability To Pay (ATP) calculations, compliance and risk assessment, Anti-Money Laundering (AML), and sanctions. They support a variety of compliance monitors, advise on trans-jurisdictional data privacy and data transfer issues, and have electronic discovery expertise that augments their forensic accounting and data analytics skills.

About Convington & Burling

Covington & Burling’s distinctively collaborative culture allows them to be truly one team globally, drawing on the diverse experience of lawyers and advisors across the firm by seamlessly sharing insight and expertise.

Their ability to combine the tremendous strength in their litigation, investigations, and corporate practices with deep knowledge of policy and policymakers is what sets them apart and makes them one of the world’s leading regulatory practices.

This enables them to create novel solutions to their clients’ toughest problems, successfully try their toughest cases, and deliver commercially practical advice of the highest quality.