Fcpa Compliance Report

One of the more prescient authors I know is Ryan C. Hubbs, who in 2014, wrote an article for Fraud Magazine entitled “Shell Games”. Shell companies can come in different shapes and sizes. Shelf companies are those formed but not used for a long period of time. This provides the facade of appearing. Finally this type of fraud needs directors and nominees to fill out the package and provide the aura of legitimacy. The final area of concern is ‘hot spot’ or one location which is the home for multiple shell companies.  In your basic research do not limit your search to the International Consortium of Investigative Journalist’s database of companies listed in the Panama Papers themselves. Initially this database is reported to only have listed 5-7% of the world’s shell companies. Some of the basic questions you should be looking at from your own data and information such as information mis-matches around address, phone, fax, ship to, bank, cell contact.  Also consider whether incoming/outgoing wire transfer docum