Fraud Eats Strategy
Fraud Eats Strategy explores the world of financial crime and corruption, from crime families and penny stock boiler rooms to international money launderers, narco-traffickers, oligarchs, dictators, warlords, and kleptocrats. Each episode distills real experiences — accounting scandals, arrests, search warrants, and lost market cap — into lessons about how fraud risk can derail a strategy. The series argues that ignoring fraud and corruption risk can upend even the best-laid plans and lead to disaster. It is aimed at listeners who want a clear-eyed look at how criminal networks and corrupt actors operate inside markets and institutions.
Episodes
Leading in a Crisis: Confronting Violence in the Workplace
Workplace violence is the third-leading cause of death in the workplace in the United States. According to the Bureau of Labor Statistics, of the 5,283 fatal workplace injuries that occurred in the United States in 2023, 740 fatalities were due to violent acts. Homicides (458) accounted for 61.9 percent of violent acts and 8.7 percent of all work-related fatalities. While it is not something anyon
Braving Brazil - Operating in the Latin America's Largest Economy in Uncertain Times
Brazil is a wild and wondrous country. The people are passionate, the celebrations spectacular and the history is rich. There’s a reason Brazil is Latin America’s largest economy. But investing and doing business in Brazil is fraught with rapidly changing, multi-faceted risks.
Before 2014, there had been zero prosecutions under the country’s anti-bribery and corruption laws. Then the Lava Jato /
The Rise of Whistleblowing and Retaliation Across Latin America
It is fair to say that whistleblowing across Latin America has caught on. In fact, according to NAVEX’s 2025 Regional Whistleblowing & Incident Management Benchmark Report, a median of 2.97 out of each 100 employees submitted whistleblower reports last year. While that may not seem high, it is the highest region by far in NAVEX’s study when compared to the global median of 1.57 or the lowest of t
Do High Performers Pose Greater Risk?
So as we approach year end, many organizations are conducting performance evaluations and are allocating the bonus pool accordingly. And during the performance review process, low performers garner a lot of negative attention as you might expect. Indeed, one of the more widely recognized red flags in efforts to identify fraud risk is that of a disenfranchised employee, often a subset of the low pe
The Crypto Cringe - Why People Still Avoid Crypto Currency
I think for a lot of us, when we think about crypto, it still makes us cringe a little bit. And the question and the topic of today's episode is, should it still make us cringe?
Whether you're a fan or you're shying away from it, the crypto ecosystem is expanding rapidly. Part of what is causing many to spurn crypto is due to reputational issues. These include the prevalence of crypto-themed fra
Blacklisted Banks and Foreign Terrorist Organizations: Still Want to Invest in Mexico?
Mexico is a critically important trading partner with the U.S. Together with China and Canada, the three account for 36.5% of all U.S. imports and 32.1% of all U.S. exports amounting to over $1 trillion of trade each year. And yet, Mexico is always a challenging country in which to do business. The gap became the wealthiest and the poorest is enormous. Violent crime and gun violence is extremely
The 10 Keys to Successful Investigations: A Crossover Edition of the Fraud Eats Strategy (Scott Moritz) and Nota Bene (Scott Maberry) Podcasts
In this special crossover episode, Scott Moritz, President of White Collar Forensic LLC and host of the Fraud Eats Strategy, and Scott Maberry, host of the Nota Bene, discuss important considerations in internal investigations and how integrating each into your process can improve efficiency and lead to better and more consistent results.
Without Fear or Favor: The Last of the Watchdogs Revisited
In March of 2025, Former Inspector General of the Department of the Interior Mark Lee Greenblatt and I discussed the firing of the Inspectors General and its far-reaching implications for the country.
With the blizzard of Executive Orders, high profile government firings and other maneuvers that appear to continue to tear down government agencies, it would be easy to forget about firing of the I
Monitorships and Leniency Agreements in Latin America
Petrobras, Braskem, Odebrecht, Stericycle and other U.S. style compliance and regulatory actions continue to be more commonplace across Latin America in the past decade.
Indeed, there has been a tectonic shift in the implementation of leading industry compliance program overhauls following significant investigations and prosecutions. Some of those matters have included the use of legal tools suc
Exporting Compliance – Conducting Compliance Investigations Across Latin America
The world is a turbulent place in 2025 and doing business outside of the U.S. means needing to understand and to be able to react to a dynamic and evolving risk environment. The many countries and amazing people comprising Latin America are an important customer base and trading partner for most global organizations. Many global businesses have significant operations in the region and despite the
The Last of the Watchdogs
On inauguration day, President Trump rescinded numerous Executive Orders from prior administrations including one in which appointees within each Executive Branch Agency was required to sign a pledge not to accept gifts from lobbyists, recuse themselves from matters related immediate former employers or clients for 2 years, and not to participate in any matter for which they lobbied the government
Pig Butchering: The Intersection of Romance Fraud and Human Trafficking
Of the various fraud scheme names that have been coined over the years, “Pig Butchering” is one that provokes the most visceral response based on the name alone. And yet, the actual act of Pig Butchering is even more horrible than the name suggests. It is the latest variation of an age-old type of crime under the umbrella of “Romance Schemes”. People who prey on the lonely and elderly pretending
The Existential Threat of China
A discussion on China's state-sponsored theft of intellectual property from the U.S. and other leading economies with guest Frank Figliuzzi. Frank is a national security contributor and regular columnist for NBC News and MSNBC. He was the assistant director for counterintelligence at the FBI, where he served 25 years as a special agent and directed all espionage investigations across the governmen
After the Fraud: Recovering Losses in an Insurance Claim
Losses from a major financial crime can have a long term, negative impact on an organization. The odds of recovering those losses are not great. In fact, many fraudsters embark on their criminal path because of the financial wreckage that is their personal lives. Divorces, job losses, health crises and addictions often cause otherwise decent, law-abiding people to lose their minds, become despera
Avoiding Trial by Fire: A Primer on Crisis Communications
“It's better to keep your mouth shut and appear stupid than open it and remove all doubt”. Certainly, this quote, who depending on who you ask is attributable to Mark Twain, Abraham Lincoln or Confucius, is a great way to encapsulate the importance of crisis communications.
We have all seen examples of how things can go from bad to worse when someone steps to the podium during a crisis that is
Interview Techniques & Detecting Deception on Zoom
In this episode, we talk about remote witness interviews and how to make the best of a bad situation using time-tested interrogation techniques and other methods. While things are starting to return to something resembling normal, our use of video conferencing as a business tool is here to stay. I’ve been fielding a lot of questions about use of body language and other techniques to try to limit a
Open Source Intelligence: The Tip of the Compliance Spear
Some human beings are wonderful. Some are middle of the road and some are truly terrible. Terrible human beings are frequently indistinguishable from wonderful ones. How can we tell them apart? In the context of business relationships, the tip of the compliance spear in attempting to separate the good from the bad is frequently open source intelligence investigations. Sometimes referred to as inve
Bullet Proof FCPA Due Diligence
In this episode we going explore “bullet-proofing” your FCPA acquisition due diligence, merger integration and the government’s recent revisions to the FCPA Resource Guide and Evaluation of Corporate Compliance Programs guidance. Gone are the days when the potential bribery and corruption risk of an acquisition can afford to be something assessed at the 11th hour or not at all. Successor liability
Less Perilous Harbor: What DOJ's M&A Safe Harbor Portends
Successor liability under the Foreign Corrupt Practices Act has been a risk for companies since the statute was first enacted. But until recently, the DOJ and SEC have been deliberately vague in terms of the guidance offered and their expectations about FCPA due diligence and the time imperatives surrounding post-merger integration as it relates to combining compliance programs. That all changed i
Deconstructing the Minds of White-Collar Criminals
In this episode, we delve into the psychology of white-collar criminals. White-criminal criminals are often treated differently than other categories of criminals which provokes a response unlike other crimes. White-collar criminals are not better than or more deserving of leniency than other categories of criminal, it’s just that they are wired differently and understanding that fact can better p
Curbing Crypto Crime: The Role of Crypto Exchanges in Helping Enforce the Rules of the Road
In this episode we have an ambition agenda. We are going to provide a high level overview of virtual currencies, blockchain technology and the vital role of crypto exchange, touch upon some spectacular failures in the crypto space, how the incidence of crypto crime is going down and the role that exchanges like Binance are playing in the mitigation of crypto crime.
Evil on the Open Road: Inside the FBI's Highway Serial Killer Initiative
The FBI’s Behavioral Science Unit and Violent Crime’s Apprehension Program (ViCAP) help coordinate cross border violent crime by assisting police departments with behavioral science profiling and by maintaining a massive law enforcement database on unsolved violent crimes largely serial murders.
Joining me today is former FBI Assistant Director Frank Figliuzzi. In total, Frank served as a specia
Human Trafficking is Everyone’s Problem: Steps that Organizations Can Take to Disrupt Human Trafficking
Human trafficking is the fastest-growing transnational crime with more than 25 million people held in forced labor and sexual exploitation. As if these numbers aren't horrifying enough, 10 million of those trafficked people are children, and yet rarely are US organizations focused on human trafficking's impact on their operations, much less society as a whole. In fact, most of us consider human tr
Investigation Challenges: The More Things Change, the More They Stay The Same
Host Scott Moritz was a guest speaker at the October NAVEX Next Virtual Conference joined by Gregory Coleman, a former FBI colleague, to discuss established investigation techniques and how some of these practices have changed in recent times.
For more information visit: whitecollarforensic.com
Navigating the Steps of an FCPA Investigation - Part 2
In Part 2 of this series we continue the conversation of how to bring order to the chaos of the early days of an FCPA investigation.
For more information visit whitecollarforensic.com
Bringing Order to the Chaos: Navigating the Steps of an FCPA Investigation
In part 1 of this Fraud Eats Strategy series, we discuss how to bring order to the chaos of the early days of an FCPA investigation and avoid mortgaging the company’s future in the process.
For more information visit whitecollarforensic.com
The Anatomy of a Ransomware Attack - Part 2
In part 2 of this series, we continue to discuss the tools that cybersecurity teams use to combat ransomware attacks.
For more information visit whitecollarforensic.com
The Anatomy of a Ransomware Attack - Part 1
Ransomware is a type of malware used by criminal organizations to gain unlawful access to computer networks and encrypt the data stored on those networks and render it unusable. The criminal organization then holds the data hostage until a ransom payment is made. If the ransom is not paid, the victim organization’s data will either remain encrypted and unusable or it could be released to the publi
The 3 Regulatory Mandates Banks Fear the Most: Monitorships, Lookbacks and KYC Remediations
Monitorships, transaction lookbacks and KYC remediations are the equivalents of a regulatory vote of no confidence. They can be incredibly disruptive, painful and can cost millions of dollars to implement. They are extreme measures that are taken when regulators have seen no improvement in succeeding regulatory exams or sometimes happen without warning when a criminal investigation reveals how an
Operationalizing Compliance
This episode features special guest Tom Fox, founder of the Compliance Podcast Network and Author of The Compliance Handbook: A Guide to Operationalizing Your Compliance Program.. Click the link for 20% off of your purchase.
The discussion focuses on the guidance compliance officers can use as roadmaps when architecting their Ethics & Compliance programs and anti-bribery and corruption compliance
Investigations for Non-Investigators: Holding Down the Fort
Internal investigations often are conducted by company personnel who may not have investigative backgrounds. While that is a common scenario and perfectly appropriate, there are certain dos and don’ts that non-investigators should know about to avoid missteps that could undermine the investigation and limit its effectiveness.
For more information visit: whitecollarforensic.com
Pawns, Goofs, Collaborators and Lone Wolves: An Examination of Insider Threats
In this episode, we’re going to discuss insider threats. The term means different things to different people. Broadly, the term refers to any person or entity who has trusted insider access behind an organization’s firewall or inside their secure perimeter. “Insiders” include employees, officers, contractors, temporary workers, and certain categories of vendors and suppliers that either have unesc
Keeping Criminality Out of the Casino
Las Vegas has come to symbolize the commercialization of gambling. Casino gaming has become an extension of the global hospitality and tourism business While the mob may not be the factor it once was, criminals are still attracted to casinos and as a result, illicit money still finds its way into casinos banks despite their devotion of considerable compliance and anti-money laundering resources d
Destigmatizing Whistle-Blowers: The SEC's Office of the Whistleblower 10 Years In - Best Practices for Companies in a Brave New World
The passage of Dodd-Frank represented a major overhaul of U.S. financial regulations. Among the Act’s most notable achievements were the creation of the U.S. Securities and Exchange Commission (“SEC”) Office of the Whistleblower and the SEC Whistleblower Program. In its short, 10-year history, the SEC Whistleblower Reward Program has been extraordinarily successful in enabling the SEC to root out
The Return of the Road Warrior: What to Expect from the Resumption of Business Travel
In this episode, we're going to discuss the resumption of business travel and what that means to all of us.
For more information visit: https://whitecollarforensic.com
Brazil is not for Beginners: Operation Lava Jato Part 2
Part 2 of this episode series continues the deep dive into Lava Jato or Operation Car Wash, the largest and most complex corruption investigation in the history of Brazil.
For more information visit: https://whitecollarforensic.com
Fixing Brazil: Operation Lava Jato and How it Has Forever Changed Latin America
In this episode, we’re going to discuss Lava Jato or Operation Car Wash - the largest and most complex corruption investigation in the history of Brazil which to date has spread to 11 countries, mostly in Latin America. When the Organisation of Economic Cooperation and Development – the OECD – published the Foreign Bribery Report in 2014 examining corruption enforcement across the world, Brazil wa
Part 2 - A Recap of The First 30 Episodes
When we launched the “Fraud Eats Strategy” podcast, we promised to explore organized crime, boiler rooms, money launderers, warlords, kleptocrats and fallen CEOs, and the companies that have been damaged or destroyed through their criminality. Throughout the first 30 episodes, we hope that you have seen these efforts and enjoyed the content!
For more information visit: https://whitecollarforensic
Fraud Eats Strategy - First 30 Episodes Recap - Part 1
When we first launched the “Fraud Eats Strategy” podcast series, we promised to explore organized crime, boiler rooms, money launderers, war lords, kleptocrats and fallen CEOs, and the companies that have been damaged or destroyed through their criminality. In the first 30 episodes, I like to think we’ve delivered on that promise.
For more information visit: https://whitecollarforensic.com/
Raising the Board's Compliance IQ: Meeting Increased Compliance Expectations
Beginning in November 2012 with the publication of A Resource Guide to the U.S. Foreign Corrupt Practices Act (commonly referred to as the FCPA Resource Guide), the U.S. Department of Justice and the Securities Exchange Commission have regularly been publishing useful and informative guidance on the elements of effective compliance programs and the Department and the Commission’s expectations. Fol
The Achilles Heel of FCPA Compliance: Bribe-Paying Third Parties
Rarely do we hear or read about the names of third-party bribe payers or the names of their companies. Global companies, particularly those who ship products internationally or rely on third-parties in other ways to bring their products and services to market, are heavily reliant on virtual armies of third-party intermediaries to operate internationally. They are a necessary evil who can act on an
Chasing Bernie's Billions: Part 2
Part 2 of the special edition episode we continue the discussion of the most comprehensive and successful financial investigation and asset search in history; The Madoff Ponzi Scheme.
For more information visit: https://whitecollarforensic.com/
Chasing Bernie's Billions: An Examination of the Largest Asset Recovery Effort in History - Part 1
Arguably there is no more major a case in modern history than the Ponzi Scheme perpetrated against thousands of victims for more than three decades by the notorious Bernie Madoff.
For more information visit: https://whitecollarforensic.com/
How Transparent is the Corporate Transparency Act
On April 3rd, 2016, information about 214,488 offshore companies established by Panamanian law firm Mossack Fonseca was leaked. Since the Panama Papers leak, a total of 81 jurisdictions worldwide have passed laws requiring beneficial ownership to be registered with a government authority. The U.S. Government has been openly critical of countries that act as money laundering safe havens and yet we
Examining Siemens' Remarkable Turnaround Pt. 2
In the second part of this series, we discuss some important work my guests are involved with at the IBA’s Subcommittee on Non-trial Resolutions of Foreign Bribery Cases regarding the growing international use of settlements to resolve anti-corruption cases.
For more information visit: https://whitecollarforensic.com/
From Systemically Corrupt to Above Reproach: Examining Siemens' Remarkable Turnaround
In 2006, Germany-based Siemens was ranked 22nd on the Global Fortune 500 with revenues of $100 billion. It was a global leader and one of the world’s most admired companies. Until November 16, 2006 when the Munich Police Department raided Siemens corporate offices and several subsidiaries based on whistleblower allegations of bribery and misuse of funds. This Munich Police Department investigation
Crisis Communications 101 - How Not to Make the Crisis Worse
In this episode, we’re going to talk about the inter-relationship between major investigations and crisis communications. So much of crisis management planning and crisis communications is about thinking through various scenarios that could play out and then formulating a game plan for each.
For more information visit: https://whitecollarforensic.com/
The Maturation of U.S. Anti-Money Laundering Laws - Part 2
Part 2 of this Fraud Eats Strategy series, Scott Moritz continues the conversation on the Anti-Money Laundering Act of 2020 (AMLA 2020) with Matt Biben, Partner of Gibson Dunn.
For more information visit: https://whitecollarforensic.com/
Wiseguys, Drug Lords & Terrorists, Oh My! The Maturation of U.S. Anti-Money Laundering Laws
In this episode, we’re going to discuss the Anti-Money Laundering Act of 2020 (AMLA 2020). This is the most comprehensive set of reforms to U.S. anti-money laundering (“AML”) laws since the passage of the USA PATRIOT Act in 2001. While there is a lot to the Act, there are some important changes and enhancements that should have an immediate and long-lasting impact on anti-money laundering.
For m
The Third Line: The Critical Role of Internal Audit in Cyber Defense
Cybersecurity is at the top of most organizations’ list of critical risks and is often cited by C-suite executives and Board Members as their gravest concern. Threats that are this complex and amorphous require strong partnerships including the inside of the organization. At first glance, cybersecurity and internal audit would seem to have very little in common or little need to interact with one
The Inherent Challenge of Thwarting Trade-Based Money Laundering
In this episode, we discuss trade-based money laundering. According to the intergovernmental money laundering and terrorist financing watchdog the Financial Action Task Force (FATF), there are three primary methods that transnational criminal and terrorist organizations utilize to launder the proceeds of illicit activity and use illicit proceeds to finance terrorist operations. 1. Through the use
The Missing Private Banker: When Bank Fraud Takes a Dark Turn
The Carrasco case is a cross-border financial crime that is worth revisiting. Its lessons remain as relevant today as they were in 1998 when the fraud first erupted.
For more information visit: https://whitecollarforensic.com/
Cross Border Investigations During the Age of COVID
Conducting investigations in certain parts of the world can be challenging because of the business practices, language barriers and cultural differences. In some of those countries, they are discouraged or even unlawful. When you overlay travel restrictions during a global health crisis, challenging doesn’t begin to describe it.
In this episode, we discuss how global organizations are a microco
Financial Investigations Units and Special Investigations Units investigate threats against the institution and its customers
Most financial services companies above a certain size have one or more Financial Investigations Units (FIUs) and Special Investigations Units (SIUs) to investigate various threats against the institution and/or its customers. The missions vary from those that narrowly focus on risks such as card fraud and elder financial fraud, to those focused broadly on both insider and external threats against
Is Corruption a Part of the UN's DNA?
In this episode we look inside the United Nations and its various agencies. We assess the harsh reality of endemic corruption in how governments intersect with UN agencies. Given its unique mission, the nature of how it is funded and disbursed funds largely for things such as large-scale infrastructure building, healthcare, education and peace-keeping, and the fact that its employees and officers
The Wall Street Wolfhound Explains Pump & Dump Schemes
In this episode we examine pump and dump schemes in which thinly traded penny stocks are held by unscrupulous broker-dealers through nominees who push the stock on unsophisticated investors, drive up the share prices and then sell their shares at inflated prices causing the stock value to drop significantly. The term pump and dump is not widely known outside of securities enforcement but the names
Out from the Shadows: Examining Accounting Firm "Shadow Investigations"
In this episode, we’re going to explore the little-known area of “shadow investigations” in which accounting firms oversee internal investigations being performed by outside counsel and their forensic investigations counterparts in an effort to ensure the investigation is scoped appropriately such that it will provide sufficient information for the audit partner to comfortably sign off on the audi
Why We Need Compliance Officers More Than Ever
In this episode of Fraud Eats Strategy , we discuss why we need compliance officers now more than ever. The workforce that emerges from the combination of stay at home orders and the financial crisis will be very different than ever before. Each of us is dealing with unprecedented levels of stress, anxiety, and uncertainty. These external stressors can cause people in positions of trust to suspend
Laundering Van Gogh - Is Fine Art the Next Anti-Money Laundering Battleground?
In today's episode, we examine the often opaque, secretive world of fine art and how billions of dollars, a lot of which is from unknown origins, leads to the sales of fine art. Joining us to talk about this subject is Kobre & Kim partner Rob Rathmell. Rob specializes in providing offensive, counter-offensive, and defensive strategies for high-net-worth individuals and institutions in internationa
The OFAC Enigma - When Compliance is a Moving Target
In this episode we discuss the Office of Foreign Assets Control (OFAC) sanctions and other areas of sanctions compliance and the inherent challenges of operating a company in compliance with U.S. and international sanctions when the lists of sanctioned parties are a moving target. Joining us are two experts on the subject of U.S. Trade and Economic Sanctions, Arnold & Porter Partner Baruch Weiss a
Using Artificial Intelligence to Root Out Fraud and Insider Trading
In this episode, we discuss the rapidly expanding use of artificial intelligence, machine learning and robotic process automation to undertake trade surveillance and mitigate fraud. Joining me today are two experts on the subject of Artificial intelligence from both the technical and legal and compliance perspectives.
For more information visit: https://whitecollarforensic.com
Critiquing Leadership and Living to Tell About It
In this episode, we talk about the uncomfortable and sometimes terrifying situation when a compliance officer must critique a member of leadership team and living to tell about it. In recent years, the expression “tone at the top” has been displaced by “conduct at the top” ushering in a new era of leadership accountability and transparency by the DOJ and other enforcement agencies in the U.S. and
Performing a Fraud Risk Assessment and The Unexpected
In this episode, we talk about why this may be exactly the right time to perform a meaningful fraud risk assessment. Fraud risks are like potential explosions. The vulnerability of fraud can lay dormant for years until and unless someone in a position to exploit the control weakness, formulates a rationalization and is off and running. Joining us today is Bruce Dorris CEO and President of Associat
"Mr. FCPA" on DOJ Compliance Guidance Takeaways
In this episode, we talk about the importance of seeing your compliance program through the government’s eyes. The DOJ Fraud Section recently released its latest update to their guidance on evaluation of corporate compliance programs. While it does not represent a major rewrite, it did provide further clarity on the government’s expectations on post-merger integration, continuous program improveme
Is it Possible to Monetize Effective Compliance?
In this episode, we talk about one of the more challenging aspects of regulatory compliance - measuring return on investment. Important elements of an effective compliance program include confidential reporting and investigations. Today we speak to two subject matter experts on confidential reporting, Carrie Penman, Chief Compliance Officer of NAVEX Global, a widely noted compliance luminary and K
Fraud Has No Place to Hide (in a Down Economy)
In this second episode of Fraud Eats Strategy, Scott Moritz speaks to Neil Barofsky, a partner at Jenner & Block and the former Special Inspector General of the Troubled Asset Relief Program about these issues. We will explore the increased discovery of financial crimes that occur in a down cycle of the economy and how organizations can use fraud risk assessments to identify fraud, pursue avenues
What Enron Can Teach Us About Future Frauds
In this first episode of Fraud Eats Strategy with Scott Moritz he speaks to former Enron Whistleblower Sherron Watkins about the many red flags that were ignored, the ill-fated board decisions and the wide-ranging complicity that led to Enron’s implosion.
Sherron’s memo to former Enron leadership warned of the accounting irregularities that would cause the company to “implode in a wave of accou
Introduction to Fraud Eats Strategy
In this introduction, you will meet Scott Moritz, President of White Collar Forensic. The series features a deep dive into the various ways fraud can affect each and every one of us.
Join us each week as we take a deep dive into the various forms of fraud across the world and discuss crime families, penny stock boiler rooms, international money launderers, narco-traffickers, oligarchs, dictators,
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