Corporate Compliance, Ltd.
Our Services: Featuring Action Line Hotlines
For All Businesses
For the Healthcare Industry
For Financial Institutions
For Municipalities

For All Businesses:

Corporate Compliance, Ltd. can assist you in designing, implementing and testing a compliance program to protect your organization. Our expertise with the requirements of the Federal Sentencing Guidelines for Organizations will help you to select the compliance mechanisms that will work for your organization and satisfy the government's criteria for an effective compliance program.

One of the key ingredients of an effective compliance program is the creation of a system which employees can use to report legal and ethical violations, without fear of retaliation. One of the most effective ways to achieve this goal is by utilizing a HOT LINE service.

Corporate Compliance's Action Line is a live "800 number" hot line. Our experienced staff is available to advise our clients 24 hours a day, 365 days a year. The Action Line is confidential. Since the Action line is run by an independent outside firm, your employees can trust in Action Line and are not afraid that reporting a violation will lead to retaliation.

Monitoring and auditing are other essential features of an effective compliance program. Monitoring is organizational oversight designed to promote compliance with the law and applicable ethical standards.It involves forensic auditing, which is far more involved than the typical annual financial audit many companies have performed by a certified public accounting firm.The forensic auditor uses investigative methods to detect fraud, including obtaining evidence, taking statements by utilizing fraud assessment questioning, writing reports, testifying to findings, and assisting in the detection of fraudulent activity in the future.

Besides being an integral part of a compliance program under the Guidelines, an effective monitoring program represents sound management practices. In the long run, it saves money. An organization with a proactive monitoring system has control over fraudulent and/or unethical practices by employees, agents, vendors and others. Organizations with codes of conduct and monitoring systems not only have improved internalcontrols, but also give a strong message about the organization's ethical culture to employees and to the community that they serve. A strong reputation for integrity may help protect the organization from those who might be tempted to victimize it.

Corporate Compliance, Ltd has an interdisciplinary team of experts: Certified Fraud Examiners, legal, auditing, investigative and hospital management personnel adept at detecting areas of potential liability.The background and experience of our team represents many years of detecting fraudulent conduct as special agents and auditors of the various state and federal regulatory agencies by which they were previously employed.

To discuss our services in greater detail, you may reach us by email by clicking here. We can also be reached by telephone at (845) 225-6822, or by mail at the following address:

Corporate Compliance, Ltd.
152 Kentview Drive
Carmel, NY 10512

For the Healthcare Industry:

Healthcare fraud costs billions of dollars annually, and is being aggressively investigated and prosecuted by the FBI, the Department of Health and Human Services, the Internal Revenue Service and the Postal Service. Those who are caught cheating the healthcare system have tremendous civil and criminal exposure. For example, one organization was hit with a fine in excess of $100 million in connection with civil Medicaid fraud charges, and several of its executives have received prison terms.

Today, physicians, hospitals and insurance companies must be on their guard to avoid being victimized by fraudulent schemes. They must take steps to ensure that neither they nor their employees engage in activities which may seem permissable, but which may ultimately be considered fraudulent under the federal fraud and abuse laws.

Any organization which does not have a compliance program in place to prevent, detect and report criminal conduct is at risk.

Corporate Compliance, Ltd. can help your organization to significantly reduce its exposure by implementing an effective compliance program targeted to your needs. In addition to our general services, Corporate Compliance, Ltd. offers a cost-effective, industry specific hot line service. Consultantsexperienced in the medical profession answer phones, 24 hours a day, live- No machine. Our Medical Ethics Action Line can help you with:

Our Medical Ethics Action Line gives your employees a feeling of trust and confidence since it is staffed by independent outside consultants, and saves you money.

In addition to our hot line service, Corporate Compliance Ltd can assist you with an organizational monitoring programto detect problems in high risk areas such as:

To discuss our services in greater detail, you may reach us by email by clicking here. We can also be reached by telephone at (845) 225-6822, or by mail at the following address:

Corporate Compliance, Ltd.
152 Kentview Drive
Carmel, NY 10512

For Financial Institutions:

Financial Institutions, like other organizations, are subject to vicarious liability under the doctrine of respondeat superior. That is, the institution may be held responsible, civilly and criminally, for the misconduct of its agents and employees when their wrongdoing occurs within the scope of their employment. This is true even in cases where the institution was unaware of the criminal activity of one "bad apple".

Employees are often aware of unethical or illegal behavior long before itcomes to the attention of management. They repeatedly comment that they do not report such activity because they do not know who to approach, or are afraid of retribution.

Our Financial Institutions Ethics Action Line is a vital component of an effective compliance program under the Federal Sentencing Guidelines because it gives your employees a confidential, nonthreatening way to report violations. We do not even ask callers for their names, so as to protect their anonymity.Calls are not recorded. Our Action Line staff will make notes of the detailsof the call and promptly report the allegation to management.

In the area of federal criminal law, Title 18 of the United States Code containsa number of provisions related directly to financial institutions. Corporate Compliance, Ltd can assist your institution in conducting a risk assessment analysis and design,implement and test your compliance program.

Financial Institution Ethics Action Line is designed to provide a reporting mechanism for banks (national banks, state chartered banks, and federal and state chartered thrift institutions) and non-bank financial institutions and businesses (securities broker?, currency exchanges, dealers in precious metals, pawn brokers, auto dealers, etc.).

Don't be mislead, what you may expect may not be true.

Banks are highly regulated financial institutions, subjected to frequent examinations by governmental agencies and annual audits of their financial statements by a CPA firm. However, the greatest danger facing bank management is a sense of complacency that the regulators and CPA auditors somehow function to detect and prevent fraudulent activity. The financial audit by the CPA firm is conducted to ensure that the financial statements properly reflect the institutions financial condition and that the statements were prepared in accordance with generally accepted accounting principles. Fraud detection is rare simply because it is not the focus of the CPA firms engagement. Recently, issues of fraud detection have begun to be addressed by CPA firms conducting their audits, however, issues of fraud prevention, remain unresolved.

A compliance program under the Federal Sentencing Guidelines is designed to prevent and detect violations of law. The greatest risk of criminal activity for financial institutions today is in the area of money laundering. Unfortunately most financial institutions feel compliance in this area need only be attained by the filing of CTR's (Forms 4789) and training personnel in the forms preparation. Corporate Compliance, Ltd. staff of former federal law enforcement personnel have years of professional experience in investigating money laundering and other complex financial crimes. Our consultants can assist your organization in implementing a program to prevent money laundering activity or to detect current or past money laundering transactions.

Money Laundering

The Greatest Risk to Financial Institutions

Money laundering has been referred to as the crime of the 90's and represents the greatest risk to financial institutions. Currency produced from narcotics and other illegal activities, and the use of the world financial community to conceal the source and origin of these unusual or extraordinary cash activities, has placed financial institutions at the core of the money laundering process.

Money laundering can be defined as the disguising of the existence, nature, source, ownership, location and disposition of property derived from criminal activity. The term "laundering" has been used describe the process of "cleaning" of illegal "dirty" funds to make them appear legitimate or from "clean" sources.

Although narcotics trafficking probably accounts for over $400 billion a year in illicit drug activity, money laundering does not have to involve currency and is not limited exclusively to narcotic crimes. Individuals who engage in criminal activity must manipulate the proceeds of this activity so they will not be detected when they use these illegal proceeds for their personal use. Whatever financial manipulation they use, which are limited only to the extent of the launderer's imagination and creativity, will be considered money laundering, and in almost all cases will involve a financial institution. A most familiar from of money laundering would be the tax evader who may attempt to disguise the source, nature, amount, ownership or disposition of monies in order to understates income or overstate expenses. The truth is that money launderings greatest risk to financial institutions is that it takes place in almost all financial crimes, from the con man who embezzles company funds to a high ranking narcotics trafficker, they all must disguise their illegal activity and make it look legitimate. Criminal activity, which is linked to organized crime, is laundered through financial channels. These enterprises generate illegal funds from loan sharking, illegal gambling, fraud, extortion, corruption, illegal trafficking in arms and human beings, prostitution, counterfeiting, organized motor vehicle theft and other offenses.

Typically, the money launderer has the problem of having large volumes of currency, the difficulty transporting and protecting it, and the problem of converting small denomination bills to larger denomination bills, and the subsequent conversion to assets that can be invested and/or spent.

The Money Laundering Process


The initial step in the money laundering cycle involves the placement of funds. It is this step that legislation has been developed to prevent launderers from placing cash into financial institutions or bringing currency out of the country. It is at this stage that most laundering is successfully detected. This description involves a large scale laundering operation.

Placement can involve elaborate schemes using numerous techniques (mules to transport and place funds into numerous bank accounts) or it can be as simple as placing currency in safes, bank vaults or under the mattress. If the latter is true and the funds are used over time for personal use without an attempt to launder then detection will be unlikely.


Layering involves a complex pattern of financial transactions used to disguise the audit trail. This stage is the most difficult to detect especially when the complexity of the transaction involve monies that leave the jurisdiction of the United States. Layering often involves the use of hidden bank accounts, shell corporations and the use of off shore havens to disrupt the audit trail and hide the scheme from investigators. Traditional methods to move the currency involve wire transfers, physically moving the funds out of the country, cashiers check and money order, postal money orders and placing the money into trust accounts of other third parties for transfer out of the country.


The final stage in the laundering process is the integration of the assets back into the economy in such a way as to make it appear as if it was a legitimate business transaction. The integration may involve leaving the funds in a foreign country for acquiring assets, investments, or for the purpose of buying additional narcotics. When integration brings the funds back into the country they often appear as loans from fictitous foreign investors, gifts, proceeds from the sale of foreign real estate, payments for fictitious invoices, salaries / commissions paid by foreign corporations, or the physical transportation of currency back into the country of larger denomination bills. If a physical transport is done the launderer may well report its entry into the country at the border, thereby legitimizing the funds.

Financial institutions are an important mechanism for the disposal of criminal proceeds in spite of improved customer identification requirements. Banks offer a diverse range of products that can be used by money launderers. Non-bank financial institutions and businesses are becoming more attractive channels to use to place monies into other financial channels. Money remittance services, especially those in ethnic communities have a long history of being used to transfer monies between countries. Professional money laundering facilitators, such as, accountants, lawyers, financial advisors, real estate agents have been used for placement or layering of funds. Both real businesses and shell corporations have utilized various techniques to commingle and disguise illicit transactions.


Bank and non-bank financial institutions must use a proactive approach to money laundering. The focus must go beyond the regulatory minimums of CTR, suspicious transaction form preparation and training. Most of these activities fall into the category of detection when what really is needed is prevention. The establishment of strong "know your customer" policies should be supplemented with strong "know your employee" policies. An effective compliance program under the Federal Sentencing Guidelines represents the most proactive approach that can be used to prevent and detect criminal activity.

Corporate Compliance consultants can design and implement a compliance program for financial institutions that meets the Federal Sentencing Guidelines standards or review and monitor compliance programs already in place. There is no substitute for a professional evaluation of a financial institution's needs by individuals experienced to combat the sophisticated schemes and complex transactions used by money launderers.

In the absence of an effective compliance program, financial institutions face potentially staggering fines and long prison terms for these kinds of offenses.

For Municipalities:

All municipalities, whether they be cities, towns, villages or hamlets, should be aware of the doctrine of respondeat superior. That is, in situations where municipalities are victimized by public officials and/or their employees, the municipality may be held liable for the criminal activity of its officials and employees when that activity is committed within the scope of their official duties or employment.

The risks of potential fines in this area are staggering and criminal prosecutions are frequent. No municipality is immune to dishonest activities of its employees or agents.That is why an effective compliance program is necessary to limit the municipality's potential exposure.

Forensic audits can detect the following schemes that have plagued municipalities in the past:

  • kickbacks and illegal payments
  • gifts and gratuities
  • false statements and claims
  • bribery of public officials
  • conflicts of interest
  • cost discharging
  • unnecessary purchases
  • leaking bid data
  • manipulating bids
  • phantom vendors
  • false travel vouchers
  • false, inflated or duplicate invoices
  • embezzlement of public monies
  • misuse of position
  • misuse of government property.

Such illegal activity can also be detected through an effective reporting system, through which employees can report illegal activity in an anonymous manner, without fear of retaliation. Confidential hotlines such as Corporate Compliance Ltd's Municipal Ethics Action Line have proven to be successful and cost-effective reporting mechanisms.

To discuss our services in greater detail, you may reach us by email by clicking here. We can also be reached by telephone at (845) 225-6822, or by mail at the following address:

Corporate Compliance, Ltd.
152 Kentview Drive
Carmel, NY 10512

Corporate Compliance, Ltd.
152Kentvew Drive
Carmel, NY 10512
Telephone: (845)225-6822
Fax: (845)225-3930

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Text copyright 1997 by William J. Richmond and Michele C. Petitt. Graphics copyright March 1997 by Michele C. Petitt and the Village Web Smiths. The Fraud Detector is a Trademark of Corporate Compliance, Ltd. The Anvil and Keyboard Logo is a Trademark of The Village Web Smiths.
The contents of this web site are provided for informational purposes only and are not intended to constitute legal advice. Please consult a professional for assistance with your particular situation.