These are events that take place in any type or size of company, but whose effects are more noticeable and more perverse in medium, large and very large companies. In them, for example, to have a director or vice-president caught with his mouth in the bottle - or rather, with his hand in the safe - can be extremely traumatic.

Not only because of corporate crime, the amount of money or assets that such a cat may be subtracting, but mainly because corporate fraud never involves just one subject. The composition of a gang is part of the morphology of the frauds, the larger the more extensive the amount subtracted. It's touching to see good executives tearing their hair out when faced with a situation like this: it's not difficult for a fraud scheme to involve hundreds of millions of dollars, with surprising criminal consequences, and if that information falls on the market's ears... well, there goes the value of the shares, there go jobs and everything else.

Corporate Crimes

Over the course of 30 years of investigating financial fraud, I have seen such dramatic situations experienced by honest companies that they would sound, in bar talk, like the stuff of a Hollywood movie. Unfortunately, these are things that are part of reality. And so, they must be treated by companies within the real level, with all the limitations that this means. In practice, companies hire me either when they suspect that something is wrong or when they already know about the existence of corporate crimes but need to understand the extent of the damage and its ramifications. This means that I must not only do a “corporate Sherlock Holmes” job, as they once defined me, but also clear the contaminated ground so that good practices can grow back on it.

Perhaps my “clinical” practice in this silent region of corporations can be useful for honest teams, entrepreneurs, and managers who are suddenly engulfed in suspicion that something is wrong in some area of the company in which they work. Although I cannot share practical experiences - after all, my clients are at the top of the corporate pyramid and naturally do not want publicity - it is not difficult to explain some concepts that earn me gold during investigations, and that can be used to evaluate situations, reflect on them and move towards their resolution.

One of these perceptions I drew from a parallel with the “dark side” of life: that every mafia and every intelligence service has a category of professional known as a “cleaner”. No, he's not the professional killer: he's the guy whose job includes cleaning up the remnants of all kinds of dirt that appears in the organization or as a result of it. Your job is to neutralize things that threaten the integrity of the organization and to destroy traces of what happened, so that it continues to operate smoothly.

In a criminal organization or even in a “CIA” of life, this cleaning man by definition has no scruples or ethics, since the very entity to which he belongs does not profess faith in these two qualities. Bringing back my tour to the corporate world, the fact is that the figure of the “fixer”, the “fire extinguisher”, already exists in it. This is a subject that, depending on the company's philosophy or nature of the issue, solves the immediate problem with or without the use of scruples. It is important to note the expression “immediate” here. It means that this is not the guy who will seek to understand what happened and neutralize the sources of corruption or theft in the company - he goes there and solves the annoying tip of the iceberg.

I'm actually not that guy. In the name of my company there is a “surname”, which is Anti-Corruption Adviser, and some of our materials contain the perhaps enigmatic definition that I am a “special situation manager”. In fact, in essence, the work I do is well defined as a “corporate cleaner”, and my work methodology mirrors that used by the “cleaners” of the intelligence services - although with the unrestricted use of ethics, otherwise the thing doesn't work.

To an executive who is involved in seeking a resolution to a “special situation”, such as blackmail, robbery, or bribery, I suggest that they follow four basic steps that I myself use in my daily investigative work:

· assess the problem and define immediate measures to contain the situation
· then understand the problem in detail, thoroughly investigating everything related to it - implications, risks and consequences of all kinds, including strategic aspects and possible opportunities of the situation that can be explored
· create a plan of actions to neutralize and solve the problem comprehensively, in all its ramifications from the smallest points
· execute that plan

Is it a simple job? No, it certainly isn't. In cases of corporate crimes, investigations sometimes take months and can involve all areas of the company looking for details to help clarify the plot and who is participating in it. What happens when high-ranking figures from the highest dome are involved? This is one of the difficult points, and that is also why ethics and integrity are the cornerstones of my work. Without this duo, I cannot present results that will point to the culprits, perhaps in sensitive areas of the company.

But a very important thing about the “corporate cleaner” is to always keep in mind that the central objective of the investigation is to protect the company's strategic interests and to show that it does not tolerate dishonest conduct. The rest is a consequence

*Postgraduate lawyer in Economic Law from Yale Law School and Master in International Law from Cambridge, Barry Wolfe is director of Wolfe Associates (www.wolfe.com.br), a consultancy in preventive compliance, risk assessment and corporate fraud investigation.

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