SunCrest Law / Fractional counsel / Anti-corruption
Anti-corruption exposure concentrates in a handful of roles.
It is rarely the whole company. It is the international general managers, the finance staff who approve the payments, the operations people dealing with customs and licensing, and the third-party intermediaries nobody has diligenced. A program that trains everyone equally trains nobody adequately.
Who this is for
- You have international operations and a policy nobody has looked at in several years.
- Your training is a single annual e-learning module assigned to the whole company.
- You use third-party distributors, agents, or customs brokers in higher-risk markets.
- An acquisition, a new market, or a diligence request has raised the question.
What this program addresses
This program updates the policy against current enforcement posture, then does the part most programs skip: identifying who is actually exposed, and reaching them with training that addresses the decisions they face rather than a generic module.
An accounting background matters here more than it sounds. The books-and-records provisions are where most enforcement actually lands, and they read differently to someone who has closed a set of books.
What you get
Every item below is a document or a working process delivered to your team — not a memo describing what one would look like.
- Policy update
Revised against current enforcement priorities and the realities of your operating footprint.
- Risk-tiered participant map
Who needs what level of training, by role and geography, with the reasoning documented.
- Live training delivery
Delivered in person or by video to the higher-exposure population, plus a recorded module for the broader workforce.
- Third-party diligence checklist
A workable standard for intermediaries, with a red-flag guide for the people doing the onboarding.
- Escalation and reporting procedure
Where a question goes, who decides, and how the decision gets recorded.
After the program
Annual training delivery, policy refresh, diligence support on new intermediaries, and pre-acquisition compliance review.
Ongoing work is arranged separately once the program is complete, so the decision to continue is made with the finished product in hand rather than at the outset.
Relevant experience
Updated the anti-corruption policy for a NASDAQ-listed company, built the risk-tiered training population analysis across international operations, and designed and delivered live FCPA training. B.S. in accounting, Brigham Young University.
How this is priced
This program is quoted as a fixed fee, agreed in writing before any work begins. The scoping call that produces the quote is free and carries no obligation. Where a matter genuinely does not suit a fixed fee, we say so upfront rather than letting you discover it at the first invoice.
A scoping call, then a fixed fee.
Bring the messy version. Thirty minutes is usually enough to tell whether this is a program engagement, a smaller piece of work, or something you should handle another way — and we will say so either way.