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



Investigating EU Sanctions Breaches


With the war in Ukraine bringing unprecedented EU sanctions (restricted measures) against Russia this expert panel will discuss what this means for corporate investigators charged with investigating potential sanctions breaches for companies operating within EU member states.



Christoph Haid, partner, Schoenherr

Christoph joined the law firm in January 2004. He is a member of the EU & Competition department and co-heads Schoenherr’s Compliance & Investigations teams. On the competition law side, he has since been involved in numerous high-profile merger control proceedings before the Austrian competition authorities and the European Commission, and coordinated global merger control filings, particularly in CEE, where his focal point of work is. On the compliance side, Christoph is frequently involved in supporting clients to implement comprehensive compliance programmes, investigate perceived misconduct and respond to emergency situations.


Karen Williamson, Director, Deloitte

Karen has spent more than 15 years’ working in Forensics and specialises in investigations, predominantly focused on the Financial Services industry, including spending one year on secondment to the Financial Services regulator in the UK, the FCA.

Karen is a highly experienced Forensic accountant and investigator starting her career in the UK, before moving to Switzerland in 2019. Karen advises clients on matters ranging from fraud and misconduct investigations; allegations of conflicts of interest; bribery and corruption investigations; to Panama papers exposure analysis; tax evasion; and accounting investigations.


Darya Chub, Sanctions Compliance Project Counsel, BAT

Darya is a member of Central Trade Compliance Team focusing on the recent sanctions regulation evolution with primary responsibility for sanctions compliance matters.

Darya joined BAT in 2005 in Uzbekistan and since then has been responsible for supporting and counselling various markets ( Uzbekistan, Georgia, Azerbaijan, Hong Kong, Global Duty Free and UK) and functions on legal and compliance issues. In her previous role, she has been principally responsible for compliance programme in Asia-Pacific Area and Global Travel Retail. She has been instrumental in transformation of Global duty-free compliance framework,  setting it as a best practice example, compliant with ABC, AML, AFC and international sanctions regulation.


Jeff Giddings

Jeff has over 26 years’ experience leading and performing internal and external corporate investigations in the corporate sector, various United Nation’s agencies, and other international organizations. Currently, he is the Senior Investigator and Head of Investigations for the Organization for Security and Co-operation in Europe (OSCE) – the world’s largest security-oriented intergovernmental organization.








Sponsored by

Your right, your role – say no to corruption

ACi is delighted to support the United Nations International Anti Corruption Day this year.

Your right, your role: say no to corruption
Votre droit, votre défi : dites non à la corruption
Tu derecho, tu desafío: dile no a la corrupción
احفظ حقك، العب دورك: قل لا للفساد
твое право, твоя роль: скажи коррупции нет

On 31 October 2003, the United Nations General Assembly adopted the United Nations Convention against Corruption (UNCAC) and the United Nations Office on Drugs and Crime (UNODC) based in Vienna, Austria, as the secretariat to the Conference of the States Parties to the Convention. The Convention was opened for signature at a High-Level Signing Conference held in Mexico from 9 to 11 December 2003. As such, the General Assembly designated 9 December as International Anti-Corruption Day (IACD), to raise awareness of corruption and of the role of the Convention in combating and preventing it.

The UNCAC places a premium on the prevention of corruption as a fundamental aspect of criminal justice. It provides for a comprehensive range of preventive anti-corruption measures in a dedicated Chapter (Chapter II) which precedes the Chapter on criminalization and law enforcement. Several provisions of the Convention address the private sector. Among them, Article 12, under Chapter II, calls upon States parties to ensure “…that private enterprises, taking into account their structure and size, have sufficient internal auditing controls to assist in preventing and detecting acts of corruption…”. As such, the prevention of corruption is an obligation for the corporate world too.

The theme of International Anti-Corruption Day 2021 is: “Your right, your role: say no to corruption”. The key message is that a corruption-free word is everybody’s right, and that anti-corruption efforts are everybody’s responsibility – governments, companies, professions, society and individuals alike. The second key message is that policies, laws and mechanisms must be in place, in public and private sectors, for individuals to be able to speak up and say no to this crime without fear of unjustified treatment. An environment where individuals feel free to report wrongdoings, in good faith and on reasonable grounds, contributes to a culture of lawfulness and integrity. It provides a strong deterrent to corrupt practices by those who count on low detection risks if not impunity.

Giovanni Gallo will explain the ongoing role of the UNODC as the “managers” of the UNCAC, their efforts to raise awareness and promote the speak-up culture around reporting corruption and how the Convention addresses the role of the private sector. There will also be a description of a significant integrity initiative developed by the World Bank to establish longer term funding for anti-corruption initiatives. Duncan Smith from the European Investment Bank will then describe anti-corruption efforts from a multi-lateral bank perspective – investigating and sanctioning governments and corporations who engage in corrupt acts in MDB funded projects, and how they can assist in building integrity cultures in the private sector. Finally, Basha Galvin from the Association of Corporate Investigators will explain how the ACi can assist the global fight against corruption through training, education and raising of investigative standards in the corporate world.

The significant impact of corruption on society calls for each of us to play a role in its prevention. Join our high calibre and experienced speakers on International Anti Corruption Day 2021 for this ‘must watch’ webinar. 



Mr. Giovanni Gallo, Chief of the Implementation Support Section Corruption and Economic Crime Branch
Division for Treaty Affairs, United Nations Office on Drugs and Crime

Mr. Giovanni Gallo is the Chief of the Implementation Support Section of the Corruption and Economic Crime Branch at UNODC. He oversees the global delivery of technical assistance for governments to better implement the UN Convention against Corruption. This work includes the engagement of other key actors such as the business community, the academic world and civil society. Over the past 20 years, he held several positions at UNODC, both at headquarters and in the field.

From 2011 to 2019, Mr. Gallo served in the Office of the Director-General of the United Nations Office of Vienna (UNOV) and Executive Director of UNODC. He was Deputy Chief of the of the Office from 2011 to 2015, when he received the additional role of Senior Legal Adviser to the Director-General and Executive Director.

From 2006 to 2010, Mr Gallo supported Member Sates’ efforts to tackle transnational organized crime and corruption by providing normative and operational assistance in line with the UN Convention against Transnational Organized Crime and its Protocols and the UN Convention against Corruption. From 2001 to 2003, he worked for the UNODC Office in Myanmar.

Mr. Gallo is a lawyer by training and holds an advanced law degree from the University of Bologna, Italy.

Duncan Smith, Deputy Head of Fraud Investigations, European Investment Bank

Duncan Smith is Deputy Head of Fraud Investigations at the European Investment Bank. As a barrister, he prosecuted fraud & corruption in the UK. After working for the World Bank’s Investigation Unit (as Team Leader and then policy adviser), he moved to the European Investment Bank to address outreach, training, prevention and deterrence issues. He is a co-author of the International Financial Institution’s Anti-Corruption Uniform Framework Agreement (2006) & other harmonized Multi-lateral Development Bank documents.

Duncan has written articles for the Basel Institute of Governance and the FCPA Blog, for example: The European Investment Bank’s 2020 Fraud Investigation Activity Report is an important compliance resource;  

What Happens to Allegations of Prohibited Conduct at the European Investment Bank

A fast way to identify fraud risks and vulnerabilities: Proactive Integrity Reviews

and authored the recently published book: Promoting Integrity in the Work of International Organisations: Minimising Fraud and Corruption in Projects.

Basha Galvin, ACi Chief Operating Officer

Basha Galvin

Basha started her career with the Metropolitan Police and moved to the City of London Police Fraud Unit, covering money laundering, trade finance fraud, bribery and corruption.  Basha left the police and moved to Citigroup for four years, moving to Barclays plc in 2006 as Head of Investigations & Whistleblowing for Wealth & Investment Bank. In 2018 Basha moved to the Oil & Gas Industry as Head of Investigations for Tullow Oil Plc leaving in late 2020.  Basha is a seasoned financial crime investigator in the public and corporate sector. She has led and managed global investigations teams.  During her career, Basha has had the opportunity to work in a number of jurisdictions including the USA, APAC and EMEA developing investigation models and collating evidence for civil and criminal prosecutions.  Basha was named as one of the “Top 40 in-house” investigation professionals by Global Investigations Review.


Mark Gough,  ACi Regional Advisor

Mark Gough

Mark has over 35 years of professional investigation experience at both national and international levels within the public sector and private sector. Mark started his career as a counter-terrorism investigator with the Australian Federal Attorney General’s Department. From 1996 to 2008, Mark worked in the Investigations Division of the Office of Internal Oversight Services at the United Nations in New York. Mark joined Siemens in 2008 as the Global Deputy Head of Compliance Investigations and managed the Europe/Middle East/Africa investigation team from the Munich headquarters. In October 2014, Mark was appointed as the Regional Head, Case Handling Asia Australia (within the newly created Legal and Compliance – Regulatory Governance structure in Siemens AG), based in Singapore and with a regional office in Beijing. In August 2019, Mark joined Schneider Electric in Singapore as the East Asia, Japan and Pacific Compliance Officer also responsible for all investigations across the region. Mark returned to Australia in early 2021 and started his own consulting company, Gough Risk Consultancy, based in Queensland. Mark will provide the ACi with advice on corporate investigations management, investigation training (investigations and interviewing), strategic investigation policy identification and drafting, and whistleblower risk management issues.