Integrity monitoring Q&A: Insights on preventing corruption and achieving compliance

With experience as an integrity monitor during the cleanup at Ground Zero as well as experience in assisting Fortune 500 companies with anti-bribery and corruption compliance programs and with ABAC risk assessments, Joe Spinelli, Restructuring & Dispute Resolution Managing Director at CohnReznick, provides insights gleaned from his experiences monitoring compliance and preventing corruption.

Joe, you led integrity monitoring for all construction companies involved in the cleanup at Ground Zero following the 9/11 terrorist attacks. This was obviously a very large project with lots of moving parts. What is the key to successfully monitoring and reporting on a project of this scale, particularly when the project is one that is also highly visible?

Ground Zero following the 9/11 terrorist attacks was my greatest challenge as an integrity monitor. This engagement entailed 24/7 oversight of the debris removal at Ground Zero as well as the preparation of the claim to FEMA for $20 billion for the City of New York to remain operational. We had 70 professionals at Ground Zero with construction, auditing, and investigation expertise, and the success of this engagement required a coordinated and cohesive effort by all.

In addition to working as an integrity monitor, you’ve created and executed anti-bribery and corruption compliance programs for a number of Fortune 500 companies.  What are the internal red flags that business executives should be aware of that indicate a real need to root out corrupt practices and implement these types of compliance programs?

An Anti-Bribery and Corruption (ABAC) compliance program for companies should be predicated on the findings of the specific risks of corruption and bribery facing that company. These risks are derived from the types of operations, business location, company size, as well as the use of agents, vendors, supplies, and distributors. An ABAC risk assessment allows the company to prioritize risks and places it in a position to demonstrate that it made a proactive good faith effort to assess its risk and insert internal controls to enjoin corruption.

What role do you think technology will play in the coming years in more efficiently identifying corruption, monitoring compliance, and enabling executives to act swiftly to mitigate exposure for their businesses?

The Department of Justice (DOJ) has provided guidance on the importance of using data analytics to ensure the effectiveness of a compliance program. Data analytics can accentuate how the compliance program effectively measures, reports, functions, identifies trends, and assists with monitoring. When monitoring construction projects, data analytics can be utilized to analyze vendor payments and establish benchmarks to identify and investigate fraudulent payments. Artificial intelligence and machine learning also enable companies to detect fraud more efficiently by analyzing complex patterns and anomalies in data which helps prevent fraudulent activities.


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Joseph Spinelli

Managing Director, Restructuring & Dispute Resolution

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This has been prepared for information purposes and general guidance only and does not constitute legal or professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is made as to the accuracy or completeness of the information contained in this publication, and CohnReznick LLP, its partners, employees and agents accept no liability, and disclaim all responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.