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Major Embezzlements

By Toby J.F. Bishop and Donna Epps

Embezzlements are rarely large enough to cause major concern to in-house counsel, directors, officers and other members of management. But under at least four scenarios, embezzlements can threaten an entity's ability to execute its overall strategy. For example, in April 2011, regulators in one Asian country prohibited a financial services company from accepting new clients in a segment of its business where a large embezzlement had occurred. The regulator determined that the company had not implemented certain required internal controls to reduce the risk of embezzlement. In another country in Asia, foreign banks face revised regulations governing the ability to expand, following regulators' investigation of another major embezzlement. We discuss below ten actions entities can take to help mitigate the risk of major embezzlements.

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