90% of conferences on bribery and corruption are led by regulators, lawyers and others committed to the notion that human behaviour can be controlled by threats, punishment and coercion and through such things as "Anti-bribery policies".
But hold on a minute!
If you discovered a company that had an "Anti-murder policy" or one on "Anti-flatulence" what would you conclude?
The following 2 day program (PLEASE CLICK HERE) was rated as "the best ever" when held publicly last year. It takes an entirely different approach to inspiring integrity and is being held "in company" throughout 2015.
If you currently rely on an "Anti-corruption" policy and want to get it in the right frame and on the right track, please contact us.
PROGRAMMES TO BE ANNOUNCED IN SOUTH AMERICA 2015
Friday, 5 September 2014
Wednesday, 3 September 2014
ADDITIONAL MASTER CLASS ON FRAUD, CORRUPTION & GOVERNANCE
Campden Wealth has announced an additional session of Mike Comer's Master Class on Fraud, Corruption and Governance to be held in London on 6th November 2014. Please click HERE for details and a booking form. Places will be limited to 100, so if you would like to attend, best to book early.
BOOKINGS NOW CLOSED
Thursday, 7 August 2014
Application List Closed.... but...
The applications list for the three special clinics for "Ultra-wealthy family" clients of Campden Wealth on:
An additional session on "Fraud, Corruption and Governance" is being scheduled for 6th November 2014, again for a restricted group of Campden Wealth's clients.
If you, or your organisation, has not been invited to any of the above, The Grey Hawk Foundation plans to run sessions for in company groups throughout 2015 and also 90 minute free of charge clinics for professional firms and associations. These will be of special importance to investigators and lawyers who are charged with the duty of interviewing people suspected of criminal offences and where cautions and "Upjohn Warnings" need to be administered.
The updated sessions incorporate recent decisions on Legal Professional Privilege (LPP), self-disclosure of suspected offences to regulatory agencies and the pros and cons of breaching the well-established principles of "separation of powers" by retaining law firms to investigate, defend or prosecute cases of suspected skulduggery. Such retentions are especially important in the light of
(a) the recent acquittal of Mr Victor Dahdaleh resulting from the refusal of opposing legal advisers to testify and;
(b) decisions in the failed SFO prosecutions of the Tchenguiz brothers;
(c) the SFO's recent pronouncement that it expects defendants to waive what it clearly regards as "dubious" Legal Professional Privilege over interview notes and investigation reports whether conducted by legal advisers or not.
If you would like more information about the public programmes , please contact Thegreyhawkfoundation@btconnect.com or info@cobasco.com.
- Finding the Truth: Verbal Judo and Tongue Fu (VJtf)
- Fraud, Corruption and Governance
- Investigating Fraud and Corruption (Advanced Programme)
An additional session on "Fraud, Corruption and Governance" is being scheduled for 6th November 2014, again for a restricted group of Campden Wealth's clients.
If you, or your organisation, has not been invited to any of the above, The Grey Hawk Foundation plans to run sessions for in company groups throughout 2015 and also 90 minute free of charge clinics for professional firms and associations. These will be of special importance to investigators and lawyers who are charged with the duty of interviewing people suspected of criminal offences and where cautions and "Upjohn Warnings" need to be administered.
The updated sessions incorporate recent decisions on Legal Professional Privilege (LPP), self-disclosure of suspected offences to regulatory agencies and the pros and cons of breaching the well-established principles of "separation of powers" by retaining law firms to investigate, defend or prosecute cases of suspected skulduggery. Such retentions are especially important in the light of
(a) the recent acquittal of Mr Victor Dahdaleh resulting from the refusal of opposing legal advisers to testify and;
(b) decisions in the failed SFO prosecutions of the Tchenguiz brothers;
(c) the SFO's recent pronouncement that it expects defendants to waive what it clearly regards as "dubious" Legal Professional Privilege over interview notes and investigation reports whether conducted by legal advisers or not.
If you would like more information about the public programmes , please contact Thegreyhawkfoundation@btconnect.com or info@cobasco.com.
Friday, 20 June 2014
Giving the Game Away
A friendly and much respected competitor asked us why we gave away so much of our intellectual capital on this site.... with free publications on interviewing and interrogations, fraud detection, decision centricity, codes of conduct and other important topics. The answer is simple: we genuinely want to help with the fight against fraud, whether for a client or not.
"That's great" our competitor responded, "but you are warning the bad guys, who can plan their way around difficult questions and respond in ways you say are indicative of innocence". This is a good point if you are not an expert interrogator. Those of us who are, know that deceptive subjects cannot control all of their reactions in the "red mist" of a tough exchange. In fact the more the deceptive subject knows and worries about the clues he subconsciously radiates the better. The result is cognitive overload and increasing anxiety which, if properly handled by the interrogator, leads to the subject losing all confidence in his ability to succeed with deception. It you would like a free copy of our 80 page guide on Interviewing and Interrogations, please click here. And if you represent an "Ultra-Wealthy Family" why not join us for some really mindblowing material at three restricted one day sessions run by Campden Wealth. You can read the brochure here.
We know that by helping the victims of fraud with free information, we also assist our competitors. Some download our stuff in bulk, occasionally rebranding it under their own names. But does that worry us? The answer is a powerful "No".
Without being too arrogant we believe we are so far ahead in our understanding of fraud, corruption, deception and other skulduggery that the knowledge we do make public helps victims without compromising our competitive advantage or the mass of even better information we reserve for our Clients.
So, we hope you find material on our site useful and will give us the opportunity of working with you when the time comes. Initial consultations are free of charge, in confidence and without obligation.
If you already have a "mission impossible" case that is getting nowhere we will be happy to submit a detailed Investigation Plan: again in confidence, free of charge and without obligation.
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Monday, 17 March 2014
Presentation on Scams and Scamsters
Mike Comer is speaking at the "Family Wealth Management and Structuring Conference" organised by Campden Wealth for ultra-rich families and trusts on 8th and 9th April. His topic is "Spotting Scams and Scamsters".
Please see the tab on or website under "Training" and clinics.
Thursday, 23 January 2014
UK Bribery Act Risk Evaluation
Our experience is that Risk Managers are not always fully involved in evaluating risks of bribery and corruption. More often this critical exercise is driven by external lawyers, other advisers and compliance professionals and is directed more towards relative trivia such as facilitation payments, gifts and hospitality (in countries perceived to be corrupt) rather than the far greater exposures closer to home.
Our study of corruption and related risks with a UK public company was based on a eclectic evaluation merging qualitative and quantitative tools while discounting the more emotional one dimensional approach implied by the Ministry of Justice Guide for Commercial Organisations and other regulatory suggestions.
This week we presented our findings at IIR's Annual Risk Congress in London. These indicate that - for most large companies - after acknowledging some heavy regulatory actions for bribe payment - the most significant risks are from incoming, internal and competitive corruption.
Please click HERE for an ebook version of our presentation. The quantified results summary is at page 8.
If you would like your management team to hear the presentation - in house - please contact admin@cobasco.com.
We are more than happy for you invite your legal and other advisers (and even the SFO and MOJ) and to debate our alternative views and recommendations. Losers buy the beer!
Saturday, 16 November 2013
Training Updates
We have been working away trawling through 40 year's worth of IC and experience to develop new programs that will knock your socks off on fraud detection, inspiring integrity (rather than the usual INTOGROTY), interviews and interrogations. The new programs are sponsored world-wide by The Grey Hawk Foundation and will start in January 2014.
Please click on the Training tab on our website for further detailed program specifications or contact us at cobasco@btinternet.com.
Mike Comer's book on Bribery & Corruption (all 900 pages of it) has sold at least one copy, but has not been the greatest hit with members of the Cottage Industry who continue to hyperbolise the evils of esoteric breaches and the omnipotence of UK and American regulators.
However, we have made some progress in making people think, trashing much of the nonsense about perceived country risks, demand and supply sides to corruption and active and passive participation. Not to mention the fact that corruption in the UK is now emerging as the problem the 900 pages predicted and that so called "facilitation payments" have been correctly framed as "performance blackmail". This is a starting point.
But will the Cottage Industry listen? Doubtful: because the more its members can frighten decent companies into self-disclosing that they have given an FPO a Homer Simpson mouse mat and cough up massive penalties, the greater their professional fees and the stronger their standing- in the reciprocation market - with regulatory agencies. But at least some companies are now thinking about the hyperbolisation and conflicts of interest.
The UK continues to lead the way over the cliff over such Noble Causes as climate change (the artiste previously known as global warming until it was proven not to exist), foreign aid, kleptocracy, nepotism, revolving doors and subtle forms of reciprocation. Most conference organisers are not keen to hear any dissenting view on bribery, corruption and noble causes and you may have noted that 99% of speakers and delegates are Cottage Industry members.
However, Informa has taken a big step and invited Mike Comer to present his views at the Risk Management Congress in January 2014. Click here to see the brochure and if you decide to come along, bring a big hammer.
Please click on the Training tab on our website for further detailed program specifications or contact us at cobasco@btinternet.com.
Mike Comer's book on Bribery & Corruption (all 900 pages of it) has sold at least one copy, but has not been the greatest hit with members of the Cottage Industry who continue to hyperbolise the evils of esoteric breaches and the omnipotence of UK and American regulators.
However, we have made some progress in making people think, trashing much of the nonsense about perceived country risks, demand and supply sides to corruption and active and passive participation. Not to mention the fact that corruption in the UK is now emerging as the problem the 900 pages predicted and that so called "facilitation payments" have been correctly framed as "performance blackmail". This is a starting point.
But will the Cottage Industry listen? Doubtful: because the more its members can frighten decent companies into self-disclosing that they have given an FPO a Homer Simpson mouse mat and cough up massive penalties, the greater their professional fees and the stronger their standing- in the reciprocation market - with regulatory agencies. But at least some companies are now thinking about the hyperbolisation and conflicts of interest.
The UK continues to lead the way over the cliff over such Noble Causes as climate change (the artiste previously known as global warming until it was proven not to exist), foreign aid, kleptocracy, nepotism, revolving doors and subtle forms of reciprocation. Most conference organisers are not keen to hear any dissenting view on bribery, corruption and noble causes and you may have noted that 99% of speakers and delegates are Cottage Industry members.
However, Informa has taken a big step and invited Mike Comer to present his views at the Risk Management Congress in January 2014. Click here to see the brochure and if you decide to come along, bring a big hammer.
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