Thursday, September 8, 2016

Question and Answer: Organizations Anti-Corruption Certification Program


The AACI delivers globally a disciplined anti-corruption certification program to organizations seeking to prevent fraud and corruption inside their business processes, operations, and culture.

This certification process is the first of its kind worldwide and forms a basis for institutional change in fighting fraud and corruption. It is available to organizations of all types. The process is “principally” administered and completed online. 

As we received too many questions about this new certification program, the technical staff of The AACI addressed the substance of these matters in the following question and answer blog.

QWhat is the Corruption Prevention Management Test (CPMT)?

The AACI:  The CPMT is an online test authored by and copyrighted to The AACI. It is the core of the organizations' anti-corruption certification program. Except for the CACM members of The AACI, the CPMT is not available to individuals; it is only available to organizations ( private, public, or nonprofit) seeking to get certified through the organization anti-corruption certification program. As the exam unit of The AACI administers it, we use third party software to deliver the CPMT (software provider).

Q: What are the benefits of getting an organization certified?

The AACI: The certification process enables those charged with governance of the organization to:


1.    Evaluate and measure relevant corruption prevention knowledge
competencies of the board members, senior management and employees.
2.    Identify the strengths and weaknesses of the entity's corruption prevention knowledge that is necessary for preventing fraud and corruption.
3.    Select appropriate responses to address identified corruption prevention knowledge weaknesses.
4.    Set apart the organization as taking the risks of fraud and corruption seriously from those that do not.
5.    Support the board members, executive management, and other decision makers to meet their fiduciary and legal duties.
6.    Support organizations to show their sincere duty of care efforts to protect the interests of all stakeholders.
7.    Help those charged with governance to set a proper tone at the top.
8.    Support an effective implementation of and compliance with corporate governance code or principles.
9.    Support an effective implementation of comprehensive anti-corruption policy, internal control and processes, and code of ethics (conduct).
10.Support the organizations to comply effectively with the requirements of ISO 37001: anti-bribery management systems.

Q: Are there any other benefits for stakeholders?

The AACI: Yes there are. For example, the certification 

1.    Supports regulators or chambers mitigate and control bribery, fraud, and corruption in a business sector or segment.
2.    Enables local governments or states to bring about real and visible anti-corruption efforts to be part of their local healthy business practices.
3.    Supports the investment optimization in human capital.

Q: Is there a passing score for the organization under this certification program?

The AACI: No. There is not a pass or fail score. We report on the results of the certification process and issues a CPMT certificate reflecting the score of the organization as a whole. 

Q: What are the primary topics the anti-corruption certification program of organizations tests?

The AACI: Most of the online test questions primarily deal with the following fields:

More than 80% of the questions cover the following:

1.    Anti-fraud and corruption
2.    Corporate governance
3.    Internal control
4.    ISO 37001: anti-bribery management systems

However, The rest of it touches on the following:

1.    Accounting
2.    Auditing
3.    Management and ethics

Q: The certification process requires the organization to submit management representation letter stating in it the decision makers of the organization it has so that they sit to the CPMT. What do you mean by decision makers?

The AACI: For the purpose of this certification process, decision makers of an organization are the following:

1.    Board members / partners / owner - manager
2.    Chief executive officer (CEO)
3.    Deputies of the CEO
4.    Department heads
5.    Deputies of department heads

Q: What would an organization obtain as a result of getting certified?

The AACI: The organization will get the following:

1.    CPMT Certificate (sample copy)
2.    CPMT Report       (sample copy)

Q: How would this certification program assure an organization of preventing fraud and corruption inside it?

The AACI: The certification program, on its own, will not provide any assurance of preventing fraud and corruption inside any organization. It all depends on those who are charged with governance to bring this confidence. Those who are charged with governance in any organization are responsible for institutionalizing corruption prevention and deterrence inside their organization. 

This certification program is an effective tool decision makers can use it to fight corruption inside their organization and in the organization's business dealings with all stakeholders. 

Q: How can an organization measure the impact of the certification program? 

The AACI: The answer consists of two parts: the first part is the visible one. An organization can compare its aggregate CPMT scores and CPMT reports over years and find out the results of its responses to earlier results.

For example, assume that in year 1, an organization had an aggregate CPMT score of 60% while two board members did not sit for the CPMT test- they had qualified CPMT report. After one year, this organization got certified and obtained aggregate CPMT score of 40% and unqualified CPMT report. Under these circumstances, those who are charged with governance of this organization have a duty to all stakeholders to answer for these results. 

The other part of the answer to this questions is straightforward: corruption in any organization is unknown until it is discovered. As we do not know what the corruption level was at an organization, we cannot provide any precise and conclusive evidence about the exact level of corruption level reduction this certificate program affected. 

What we are confident of is that when there is a proper tone at the top, and the top management has "real" will to fight fraud and corruption, this certification program is an effective tool to materialize their efforts. 

Q: Why is the certification program an annual one? 

The AACI: It is an annual certification program to 

1.    Maintain its credibility and public confidence in it. 
2.    Reflect changes in decision makers composition and  / or their competencies over one year period.

Q: How would an organization benefit from the certification process in dealing with its suppliers?

The AACI: When an organization gets certified, it can ask its suppliers to get certified to continue business dealings with them. Integrity and culture of vendors affect corruption risks of any organization directly. 

Q: How would a government utilize the certification program to fight fraud and corruption?

The AACI: A government and its agencies are well positioned to utilize this certification program to combat fraud and corruption effectively and efficiently. Presuming a government has a national strategic corruption prevention strategy, we believe a government can:

1.    Set the example and have all its ministries and agencies certified.
2.    Respond adequately to the results of the certification and start implementing national changes to improve its ministries and agencies score.
3.    Set the certification program as a prerequisite for private sector organizations that want to transact with the government.
4.    Start gradually requesting private sector entities to get certified.
5.    Issue adequate rules, laws, and regulations to institutionalize corruption prevention. 

Q: Will The AACI consider nationalizing the certification program to suit the local language, culture, laws, and regulations?

The AACI: In principle, yes we will. The AACI will also consider partnering with local governments or states to have a national CPMT certification program. 

Q:  How much does it cost to have an organization certified?

The AACI: The annual cost of certification depends on the number of decision makers who will sit for the test. There is also a fixed administration fee. For more information, you may contact us at Exam@THEAACI.com.

The AACI offers governments planning for nationalizing this certification program significant discount. 

###END###

Thursday, August 18, 2016

Organizations Anti-Corruption Certification Program


Starting September 1, 2016, The AACI offers globally a disciplined anti-corruption certification program to organizations seeking to prevent fraud and corruption inside their business processes, operations, and culture. This certification process is the first of its kind worldwide and forms a basis for institutional change in fighting fraud and corruption. It is available to organizations of all kinds and types. The process is principally administered and completed Online.

It is an annual certification process that shows quantitatively the collective anti-corruption knowledge score of those who are charged with governance and reports on the result.

Read more

Swiss Private Bank Linked to Malaysia Scandal


L. Burke Files, President of The AACI, is quoted in the New York Post.

"New cracks appeared earlier this month. L. Burke Files, who heads up a private anti-fraud agency, raised questions about a Cayman fund for 1MDB, the Bridge Global Absolute Return Fund.
“It was less than a month old when billions were deposited in into its accounts,” he told The Post. “The issue is that when the funds were deposited, the company had been formed, but it was not yet registered and licensed as a fund.”

Monday, August 1, 2016

Fighting Corruption in Developing Countries: Illusions and Realities


By: Mike J. Masoud, CPA, CACM, CFE, MBA
Technical Advisory Director, Middle East and Africa
The American Anti-Corruption Institute (AACI)


Developed and developing countries are presumably on the defensive line in fighting fraud and corruption. Pressures are mounting on every country to do its utmost to deal effectively with the cancer of globalization: corruption. On May 12, 2016, at The Anti-Corruption Summit in London Secretary Kerry stated “We are fighting a battle, all of us, for our states, for our countries, for our nation-state. Corruption writ large is as much of an enemy, because it destroys nation-states, as some of the extremists we’re fighting or some of the other challenges that we have faced.” This is the ever strongest message of the U.S. regarding fighting corruption. Our interpretation of this message is straightforward: a country that does not show serious efforts to fight corruption works against the international efforts of the U.S. to eradicate corruption and, at the minimum, indirectly supports extremists and terrorism.   

However, developing countries face real challenges in dealing with this complex socio-economic phenomenon amid the successive waves of globalization and information technology evolution and revolution. The severity of these challenges stems from the fact that in too many developing countries, the state / government is not accountable to its citizens. The state controls and runs its public resources (wealth) with the lowest levels of transparency to manage corruptly its people and opposition political parties ( if any). Too many developing countries govern by managing the fear of their citizens, engineering and institutionalizing nepotism, creating and maintaining their dynasties, and ruining the social values of their societies. To make it worse, even when such countries introduce certain levels of democratic practices or what they call “reforms”, their citizens are usually skeptical about the underlying motives and planned objectives. There is no “access to information, citizen engagement, and fiscal transparency”.  Corrupt governing practices usually tend to escalate in the natural resources rich countries. “Is it any wonder then that, in time, corruption becomes ingrained in the culture.”  Ed Fuller stated recently in Forbes.

Yet there has been much less discussion about the key institutional change needed to bring societies to the point where they are capable of controlling corruption and achieving good governance.” Unfortunately, many developing countries, especially Arab countries driven by the ramifications of the “Arab Spring”, reacted primitively in addressing corruption. All of a sudden, most Arab countries asserted the existence of corruption in their home countries and started to assure their public they will not tolerate corruption anymore! Some Arab countries established national anti-corruption commissions while others rushed to ratify the United Nations Conventions Against Corruption. As there are no national independently published surveys measuring the national levels of corruption, there are substantial doubts about the success the national anti-corruption commissions or all kinds of anti-corruption reforms. Developing countries rely on international agencies to opine on their levels of corruption. For example, when Transparency International issues its annual corruption perception index, these countries celebrate any improvement they achieve when they score better than other countries or their earlier score(s). What these countries should celebrate is their achievement in lowering the levels of unemployment, poverty, and income inequality, They should also celebrate the increased level of public engagement and civic society in monitoring the performance of their governments and public officials, These countries are gifted with talented youth generations that must be engaged in fighting corruption.

Corruption in developing countries and its consequences are realities representing threats to the national, regional, and international security. Yet, the ultimate beneficiaries of corruption exist within the national state borders and beyond. Panama Papers support this assertion.  The international community is sometimes passively corrupt when it endorses corrupt developing countries. Undoubtedly, this hypocrisy encourages systemic corruption in developing countries. The international community has legal and ethical obligations to expose corrupt countries and take real effective measures to put these countries on alert. There are recently voices that require having an International Anti-Corruption Court (IACC). Though this is hard to sell, we do not encourage establishing the IACC.

Fighting corruption in developing countries should always be based on and supported by the local national efforts. Unchecked local power is the number one cause of corruption. Developing countries are expected to show more than political will to fight corruption: they should show results.


© All Rights Reserved.2016.  The American Anti-Corruption Institute (AACI)

Further readings: America’s Global Corruption Crusade