December 2, 2020

Financial crime compliance professionals worldwide work diligently to prevent bad actors from wreaking havoc, whether the impact is local or on an international scale. These dedicated “cape-less crusaders” develop compliance strategies, implement effective anti-money laundering and anti-bribery and corruption programs, in addition to cooperating with regulatory agencies to enforce sanctions against all entities – countries, corporations and individuals.

LexisNexis® Risk Solutions is privileged to have our own cadre of cape-less crusaders on our Financial Crime Compliance team. In this series of “Who We Are” profiles, we learn more about our unsung heroes and their commitment to fighting financial crime.

Today we chat with Charles Thomas, who has been combatting bribery and corruption for over twelve years, and devotes endless hours to helping organizations avoid conducting business with bad people and bad companies.

Charles Thomas

How long have you been with LexisNexis Risk Solutions, Charles?

I joined the company in 2014.

Tell us about your job.

I’m involved in product design and development for due diligence, risk and compliance in the Anti-Bribery and Corruption (ABC) landscape. This overlaps with areas of supply chain, risk management and issues such as counter-slavery and counter-trafficking. I listen to customers, regulators and competitors and identify problems, find where there are gaps, and then look for ways to create solutions and fill them. Then I work with our sales team to take those solutions out to market.

How did you get into this field?

I previously performed pre-employment screening and personnel vetting. I came from the due diligence and risk world and that gradually developed into the anti-bribery and corruption (ABC) realm.

How do you explain your work to others?

That’s not easy. It’s not like saying you’re an accountant or truck driver. I tell people that I help organizations avoid doing business with bad people and bad companies. My neighbors think I’m a spy, which I find hilarious, and I do nothing to dissuade them of that idea!

What types of companies do you work with?

The mandate to comply with ABC regulations applies to almost any business whether they are an insurance company, a bank or a bakery. Our clients typically have an international footprint of some sort; they are buying raw materials from a foreign country or they are interacting with public officials abroad. It can be any type of business.

Do you find entire companies that are corrupt?

No company sets out to be corrupt. But individuals within companies can be corrupt. One person can put the whole organization at risk, causing reputational damage, financial damage, social damage and employee retention problems (no one wants to work for a company that is associated with corruption).

Organizations must have adequate controls, policies and procedures to prevent corruption. There have been cases of companies being completely exonerated because they were able to demonstrate that they had processes in place to prevent corruption, even though they failed in that undertaking.

What types of businesses are more likely to experience corruption?

Businesses that have a big disparity between the cost of production and sale price are more likely to have corruption. Think about diamonds. The jewels are dug out of deep, dirty holes by miners that may only be paid a few dollars an hour. The product then goes to the sorting house, the cutting house and finally a retailer where it might be sold for thousands of dollars. That disparity between product cost and market price creates the risk for bribery and corruption by anyone along that journey.

How often do you uncover bribery and corruption?

Most of what we do is positive, helping clients identify that their relationships are “good” ones and that is satisfying. Oddly, when there are no “red flags” appearing in a client’s world, we don’t often hear about it, but thankfully that’s the overwhelming norm. Hopefully, this shows that we are helping create a deterrent.

Do most businesses understand their responsibilities for ABC compliance?

Most clients who come to us know they must put procedures in place in their organization. They have specific problems. We help determine how our solutions best fit with what they are trying to achieve.

Other companies have no idea where to start and look to us to provide guidance on what they should do. We had a fashion label come to us, a major brand name. They were doing no third-party due diligence; nothing at all. We first had to understand their pain points. Why did a company that size have no processes in place? We had to figure out what would give them the best outcome and how our solutions fit into that jigsaw, giving them a compliant process that didn’t have a negative impact on their workflow

What do you see in the future for ABC compliance?

I see an increase in transparency helped by the growth of ABC and money laundering regulations. That transparency, combined with the exponential growth of information being available will make it ever harder for corrupt actors to fly under the radar.

Is that a good thing?

Yes, but too much information is like drinking from a firehose. You need a way to manage the data, bring it together and interpret it. You can make faster and better decisions when information is managed correctly.

What do you want people to know about ABC compliance?

Compliance is good for business. That’s the overriding message.

I remember talking to a person in a sales position at a conference. When I told him I was in ABC compliance, he said, “Oh yes, I know about compliance. Our compliance department always says, ‘You can’t do this. You can’t do that.”

ABC compliance should not be a barrier to relationships or business growth. It’s a good thing. It protects companies.

I recently spoke with a UK-based company that uses their ABC compliance as a benefit. It helps them demonstrate to their customers that they are a quality company. They do robust due diligence and supply chain checking to reduce risk and build better relationships and trust. I think that’s the right approach—ABC compliance as a competitive advantage and part of a growth strategy.

Why is your work important?

Money that goes to paying bribes or gets lost in the mists of corruption lines the pockets and funds the lifestyles of a corrupt few. That’s money that should be spent on critical government programs and projects, on legitimate business and growth. Put simply, bribery and corruption deprives honest people of crucial infrastructure, services and opportunities.

Please check back for our next installment of “Who We Are” featuring Daniel Polar, Director of Strategic Solutions, and learn more about his adventures thwarting drug cartels.

Read Charles’ blog posts:

What Are You Doing to Prevent Corruption?
5 Ways to Improve Third Party Risk Management
Capitalizing on the Shift to Contactless Due Diligence
Prioritize the Integrity of Your Global Supply Chain and Protect Your Bottom Line
Strengthening Bribery and Corruption Controls with Precise Risk Information