Investigators and the new ‘Failure to Prevent Fraud’ Offence

Whether helping large organisations prepare reasonable procedures or leading investigations when things go wrong, corporate investigators will be heavily invested in the successful implementation of the pending UK corporate ‘failure to prevent fraud’ offence.* The offence will apply to UK-based large organisations as well as offshore large organisations with business and/or customers in the UK.

But what are the views of investigators on general readiness for the new legislation? RSM and the ACi are launching a Fraud Offence Readiness Survey, giving you the opportunity to express your thoughts on the matter.

*Section 199 of the Economic Crime and Corporate Transparency Act, 2023.

Click here for the survey.

The survey runs until 20 May. The results will be discussed in a webinar on 29 May 2024.


Webinar Registration



Flip Stander,  Partner, Forensics & Investigations, RSM UK



Sam Tate, Partner, RPC



Ashu Sharma, Head of Advisory Panel, ACi



Navigating High Stakes Investigations under the Spotlight: An Interactive Case Study

Join the ACi with Ankura and Fieldfisher for an interactive workshop considering the restrictions and best practices for addressing legal and reputational risks arising at different stages of the investigations life cycle. The case study central to the in-person workshop encompasses allegations of misconduct, cross-border data collection challenges, regulatory considerations, and potential corporate financial fraud.




Participants will be split into small groups to assess and analyse a scenario based on a blend of real-life cases, whereby a Senior Business Leader is the subject of whistle-blower reports alleging bullying and harassment, with some claims suggesting potential financial fraud. Our subject matter experts will support participants through the process of successfully planning a complex and multi-faceted investigation, by walking through the following areas:

  • How to achieve effective, efficient and lawful data collection and analysis;
  • Considering a proportionate scope, and setting up appropriate investigation governance;
  • Key preliminary considerations, such as considering and recording the position around legal professional privilege, stakeholder management, considering mandatory and non-mandatory self-reporting, determining the status of key individuals, and communicating with subjects and witnesses;
  • Methodology and top tips for interviewing, with a focus on discharging the corporate duty of care, maintaining psychological safety, and vulnerable witnesses; and
  • How best to evaluate exposure, and adjust investigation objectives with regards to the relevant (or potentially relevant) legislation, regulations, and rules, as new matters come to light, and new lines of enquiry present themselves.

Throughout this training, Fieldfisher and Ankura will share their experience, drawing parallels to the case study scenario. The training will also be an excellent opportunity for you to network with peers from various industries – both during the session, and afterwards, whilst sharing a drink on Fieldfisher’s terrace overlooking the Thames.




Confide Forges Strategic Alliance with ACi to Elevate Industry Standards

Partnership with ACi’s Extensive Network to Enhance Confide’s Market Position and Product Offerings

London, United Kingdom

5 February 2024

Confide, the revolutionary governance, risk, and integrity platform founded by Wirecard whistleblower, Pav Gill, announces a strategic collaboration with the Association of Corporate Investigators (ACi). This alliance positions Confide at the forefront of industry innovation, harnessing ACi’s vast member expertise to significantly enhance its product offerings.

The collaboration with ACi, with its network of seasoned corporate investigators, opens new avenues for Confide to refine and tailor its solutions. By tapping into the deep well of ACi’s practical knowledge and experience, Confide will dramatically improve the functionality and relevance of its products, addressing the current market’s unmet needs.

Pav Gill, CEO & Founder of Confide, states, “Partnering with ACi is a game-changer for us. Besides being an industry-first, it provides an unparalleled opportunity to leverage their extensive network and insights, enabling Confide to revolutionise our offerings and better serve the investigative community and beyond.”

Ashu Sharma, Head of the Advisory Panel at ACi, adds, “Our members’ expertise combined with Confide’s innovative approach will undoubtedly lead to superior products that redefine industry benchmarks. Our joint efforts will drive unprecedented innovation and excellence in the services we provide to our members and the industry at large.”

Through this partnership, Confide aims to not only enhance its existing solutions but also to ideate new, cutting-edge tools that align with the real-world challenges and complexities faced by corporate investigators.

This strategic collaboration with ACi signifies a major leap for Confide in its mission to lead and transform the corporate investigation landscape through collaborative innovation and expertise-driven product development.

Members News Research

Member survey 2023

This June we are reaching out to members to see if they’d like to get more involved with building the ACi. As you’re aware, the Executive Committee at ACi are all volunteers, who have full-time in-house investigations roles. The popularity of the Association means we are always on the lookout for subject matter experts who are willing to share knowledge and experience, and for investigations professionals who want to give back to the profession by reaching out to their networks to expand ACi’s mission.


ACi at Relativity Fest London 2023

The Association of Corporate Investigators was out in force yesterday at Relativity Fest London 2023 as we spoke to a lively audience about our work on the development of the new ISO standard for Internal Investigations. Our panel featured Steve YoungAshu Sharma (CFE, CFCS)Hannah Clare (She/Her)William Kelly (CISM, CIPP/US) and the moderator was Simon Scales.
The panel explained how the new standard – ISO 37008 – will give organisations a guide as to how to do investigations properly. It will give investigators and their teams a source of best practice that is accepted globally, enabling them to have the knowledge and certainty that they are performing investigations to internationally accepted standards.
The panel said they have been working with a cohort of 37 countries to develop the standard, which is expected to be published later in 2023. The panel said that working collaboratively with investigators from around the world has been both interesting and rewarding. There was a standing ovation at the end of the session.

Annual Symposium

The Association of Corporate Investigators is delighted to announce its 2022 one-day symposium on Thursday, 10th November 2022 in London. Our last Symposium event was held in 2019 so we are looking forward to bringing our investigations community back together for a day of learning, networking and sharing experiences.

This year, we are kindly hosted by Allen & Overy at their London offices. This year’s theme is ‘Every Detail Matters’. As investigators ourselves, we know how paying attention to the detail is vital in an investigation. So whether that be an understanding of the rules around legal privilege, or giving a whistleblower due care and attention, it’s the investigator’s job to conduct their enquiries legally, ethically and professionally.

We have designed our event with the same attention to detail to bring you an agenda that will inspire and inform – featuring topics such as Greenwashing and Conduct Investigations, E-Discovery, Crypto Investigations, Investigations Trends and Interviewing Techniques.
The day has been built with plenty of time for networking so that you can meet your investigations peers and discuss best practices.

As always places are limited so please book early to avoid disappointment.

Member In Person Ticket –  £99 GBP
Non-Member In Person Ticket –  £199 GBP

Registration closes 4pm, Monday 7th November.

This event is paperless. View the programme here.






Banking Investigators Forum Round up

On Thursday, 26th May ACi proudly hosted its first Banking Investigators Forum event, kindly sponsored by Forensic Risk Alliance. The event was attended by banking investigators from 80 different banks and covered a range of issues, all of which had been selected by delegates as points of interest.

Our prestigious speakers included:

  • Colin Bell, CEO, HSBC
  • Stephen M Kohn, Managing Partner, Kohn & Kohn LLP
  • Jonathan Shatford, Head of Investigations, JP Morgan EMEA
  • Madalina Florea, Head of SM?MRT Investigations, Lloyds Banking Group
  • Michael Delf, Global Employee Conduct Director, Citibank
  • Charlie Steele, Partner, FRA
  • Dave Francis, Head of Litigation & Investigations, NatWest Bank Plc
  • Lorene Wiggin, Managing Investigator, NatWest Bank Plc
  • Gerben Schreurs, Partner, FRA
  • Jamie Brown, Executive Director, Head of Fraud Intelligence and Investigations, Standard Chartered Bank
  • Paul Carroll, Manager, Fraud Inestigations, Intelligence & Policy, TSB
  • Ronan Guckian, Deputy Head, Financial Crime Unit, KBC Bank
  • Magdalena Boskik, Head of RegTech and Crypto Compliance Services, Sygnum Bank
  • Katerina Androutsou, RegTech & Crypto Compliance Services, Sygnum Bank
  • Robert Clarke, Managing Director, Global Head of Investigations, Citibank
  • Cecillie Fjellhoy, romance scam victim

During the day, delegates grappled with a range of issues such as whether investigative interviews should always be recorded, the current crypto landscape and what it means for investigators, and skills and tools that investigators should have for successful outcomes.

The day was ably managed by Simon Scales who had the delegates giggling in their seats with his engaging and witty moderating style.

Feedback from attendees has been outstanding. For example one delegate said,

“The event was run really efficiently, the venue was excellent but mostly important the speakers and subject matter was just brilliant. Often I see people on their phones at lot at these events catching up with emails etc but as I looked around, like myself everyone was listening intently. It really was one of the best conferences I have attended in many years (ignoring the pandemic). Thanks to everyone involved, with a little special mention to Simon who I thought was amazing as an MC.Already looking forward to the next one, please keep my details within your database. I will be selling the events for you as I speak with all of my bank investigator contacts throughout the whole industry. So many of them would have benefitted and enjoyed yesterday.”

You can read our event programme here. Thank you to everyone involved especially our sponsor Trevor Wiles and the FRA team, Simon Scales, our speakers and not least of all the delegation who made it such a special event.

We look forward to seeing everyone next year.


Luke Cocks as Data Analyst

ACi is delighted to announce the appointment of Luke Cocks as Data Analyst.

Luke is a recent Mathematics graduate from the University of Lancaster. Luke’s work will be instrumental in helping the ACi develop products and services which resonate with our members. He will be working closely with the marketing team to devise targeted campaigns and will help ensure ACi works in accordance with GDPR rules

Please join us in welcoming Luke to Team ACi!


Jacob Atkinson as Research Assistant

ACi is delighted to announce the appointment of Jacob Atkinson as Research Assistant.

Jacob holds a degree in History and a postgraduate degree in Heritage Studies from Newcastle University. Jacob is assisting with research on certification pathways for corporate investigators, as well as horizon scanning for developments of interest to our community. Jacob also assists with research and editorial work on ACi Core Projects including the production of the Investigator Handbook. 

Please join us in welcoming Jacob to Team ACi!

Investigaciones Corporativas en Latinoamérica

La Asociación de Investigadores Corporativos (ACI) se complace en anunciar su primer evento para Latinoamérica para el día jueves 31 de marzo de 2022, el cual será auspiciado por Control Risks y desarrollará un marco general sobre las tendencias, casos más comunes y desafíos de las Investigaciones en el ámbito corporativo presentados en los diversos países de la región.




Enrique Gómez Pinzón  – Holland & Knight / Partner 

Enrique Gómez-Pinzón is the executive partner of Holland & Knight’s office in Colombia. He practices in the areas of  compliance and internal investigations, cross-border investment and financings, mergers and acquisitions, international arbitration and project finance.  Mr Gómez-Pinzón has assisted clients in coordinating internal investigations and crisis mangement response for several multinational companies with operations in Colombia. He has participated in some of the most important financings and privatizations in Colombia in the last 30 years, including licensing of cellular telephones, banking entities, power generating and distribution companies, and transportation of petroleum. He has served as an arbitrator in a variety of cases administered by ICSID, ICC, PCA, CIETAC, cases administered under the UNCITRAL Arbitration Rules and the Bogotá Chamber of Commerce. Mr Gómez-Pinzón is the sole founder and former head of one of the leading law firms in Colombia. He received his JD from Universidad de Los Andes and an LLM from Harvard University Law School in Massachusetts. He is admitted to practice law in Colombia, the State of New York and Washington, DC.

Lucas Martins – Clarios / Deputy Legal Counsel LATAM 

Lucas joined JCI in 2014 as Senior Corporate Counsel, Litigation LATAM and in 2018, was appointed Senior Corporate Counsel for Brazil Power Solutions. He has extensive experience working in Brazil and LATAM countries and has focused his practice on litigation, risk management, law department management, recoveries and business strategy. Lucas started his legal career in Sao Paulo with TozziniFreire Advogados in 1999 with a broad spectrum of litigation and arbitration cases. After working in private practice, he joined Duke Energy Brazil, as Litigation Manager in 2009. At Duke Energy, he progressively assumed more challenging roles, including real estate and environmental, compliance and investigations. In 2014 Lucas become Senior Corporate Counsel, Litigation LATAM in Johnson Controls’ Sao Paulo office, providing commercial litigation for all of JCI`s businesses in LATAM. He progressively assumed more senior roles in law department management, recoveries, material Labor & Employment matters and business partner of Power Solutions in Brazil. Lucas has a very hands-on profile, balanced with ethical and legal compliance standards and a sense of constant cooperation and partnership with business colleagues and team members. His greatest professional satisfaction is to deliver timely customer-centric work that drives business growth and he is passionate about supporting the development of his team members and colleagues. Since joining JCI, Lucas has received client recognition through several performance assessments and more recently, a Merit Award for material recoveries. He graduated Johnson Controls Leadership Edge Program (JCLE) in 2018. Lucas graduated from Pontificia Universidade Católica de São Paulo in 2001 and concluded the Master of Laws on Civil Law in 2008 He has been Professor of Civil Law and Civil Procedural Law in Brazilian and Post-Graduation Courses from 2009 to 2014 and is registered with Sao Paulo Bar Association.In his free-time, Lucas enjoys off-roading, spending time with his family, participating in triathlons and travelling. His native language is Portuguese and is fluent in English and Spanish.


Nelly Arocha – Control Risks / Director – Compliance, Forensics and Investigations 

Nelly Arocha is a Director in Control Risks’ Compliance, Forensics and Intelligence practice, based in Mexico City. Nelly is a lawyer with experience across a variety of industries both during her time with the Mexican federal government and as a consultant for Control Risks, where she has had experience conducting complex internal investigations into national and multinational companies. Nelly has more than 15 years of experience in several government postings that include the President’s Office, the Federal Institute for Transparency and Access to Public Information and the Ministries of Education and of Communications and Transport, among others. At the Federal Electoral Institute, she participated in conducting investigations in two of the largest campaign finance cases in Mexico. Additionally, as head of the Internal Control Office at a government agency, she was responsible for auditing federal expenditures and monitoring the implementation of internal controls to ensure the efficiency of the institution and prevent corruption. Her areas of expertise includes transparency and government reform, data protection, government accountability, investigations and audit.
In addition to graduating as a lawyer from the Instituto Tecnológico Autónomo de México, Nelly holds a MA in International Relations from the Fletcher School of Law and Diplomacy at Tufts University and a MSC in Comparative Politics from the London School of Economics and Political Science. She is fluent in English and Spanish.


Juliana Pontes – MercadoLibre / Internal Investigations Manager 

Juliana Marcucci Pontes Amaral es abogada especializada en derecho civil, gestión empresarial e investigaciones internas. Al largo de su carrera de 20 años, ha trabajado en estudios de abogados y desde 2009 se encuentra en Mercado Livre, donde estuvo a frente del área estratégica de Dispute Resolutions en Legales hasta 2021, cuando fue a Compliance implementar el área de investigaciones internas.



Nestor Garrido, Head of LATAM, ACi 

Nestor is a Senior Corporate Security Executive with over 23 years of professional experience in Crisis Management, Product Security, External and Internal Fraud and Compliance Investigations. From 1996 to 2005, Nestor worked in the Investigations Unit of Peruvian Navy. He started his career in the private sector in 2006 as Security Manager Peru at Novartis, conducting Compliance and Illicit Pharmaceutical investigations. After 7 years in Novartis, Nestor joined Mondelez Peru as Security Manager. Since December 2018, Nestor is currently Head of Security Peru at the multinational energy company Enel managing and overseeing Critical Event Management, Fraud Investigations and Critical Infrastructure Security. Nestor also develop training in Crisis Management, Risk Management and Corporate Investigations in association with Business Alliance for Secure Commerce (BASC). He is a Certified ISO 31000 Lead Risk Manager by Professional Evaluation and Certification Board (PECB), Member of ASIS International and ACFE.




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