A company’s ability to nip a potential anti-corruption violation in the bud is only as good as its ability to detect it. Although many organizations are now well-versed in the necessary components of an anti-corruption compliance program—e.g., sufficient resources, strong tone from the top, training in local languages, and risk-based third party due diligence—simply ticking off those boxes does not translate into an effective early warning system. Organizations can improve their chances of spotting corruption issues early, and lessen the pain of costly investigations, if they keep in mind the following guidance and incorporate it into their compliance programs.
“Shadow” Reporting Lines Can Mask Corruption Risk Many companies offer their employees both formal and informal mechanisms to report anti-corruption concerns on the premise that the more ways employees can raise those concerns, the more likely they will.
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