Guillermo Christensen Quoted in Anti-Corruption Report: "U.S. Indicts Eight Foreign Nationals in Connection with a $2-Billion Scheme in Mozambique"

Ice Miller LLP partner Guillermo Christensen was quoted in the Anti-Corruption Report article, "U.S. Indicts Eight Foreign Nationals in Connection with a $2-Billion Scheme in Mozambique." 

The article included:

Any diligence process can fail if key players in the organization, especially those in position of influence, seek to subvert or go around it,” said Guillermo Christensen, a partner at Ice Miller. “And there will often be a solid trail of evidence showing that after the fact – many emails are written by the people upset over the process ‘documenting’ their discomfort, but perhaps not so high as to hit the ‘safety stop’ on the compliance board,” Christensen said.

It is not a surprise when, especially in a larger organization, employees brush up against internal controls. “Internal controls, from my perspective, exist to be violated,” Christensen said. “One of their functions is to trip the breakers on the compliance system,” he explained. “Any decent-sized organization will be daily experiencing some level of internal-control compromise,” Christensen continued. “The important consideration is that someone is alert to the red light going on and reaches a view to whether it is serious and worthy of follow-up, or that it is perhaps an indication that a control or process needs to be amended,” he said.

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