Central Asia: Integrity Due Diligence. Third Parties Risks. Your Trusted Advisors for Central Asia International Investors Solutions: Managing Your Risks in Central Asia Doing Business in Central Asia: Kazakhstan, Kyrgyzstan, Uzbekistan, Tajikistan, Turkmenistan.

Corruption is pervasive in several countries of Central Asia, where a majority of respondents say they are either asked or are expected to pay bribes to receive public services...

If your company’s business is carried out in one of the post-Soviet Central Asian countries like Kazakhstan, Kyrgyzstan, Uzbekistan, Tajikistan, or Turkmenistan, then

Making your corporate ethics policies understood and routinely referred to by employees at your local offices in Kazakhstan, Kyrgyzstan, Uzbekistan, Tajikistan, and Turkmenistan is a huge challenge. Solving this challenge means getting rid of foreign corruption exposure

Sarsenov Corporate Governance Advisory
Compliance in Kazakhstan, Kyrgyzstan, Uzbekistan
Corporate Governance & Compliance Services
Services in Kazakhstan & Central Asia

We Help International Businesses in Central Asia

We help multinational corporations to find out solutions for their Compliance & Ethics challenges in Kazakhstan, Kyrgyzstan, Turkmenistan, Tajikistan, Uzbekistan. The major problem here is that many, otherwise robust, Compliance & Ethics Programs might easily stumble over corruption, frauds, related party transactions, collusive practices in procurements, kickbacks, companies’ property steeling, etc. Many of these things, unfortunately, been woven into local business mentality as normal way of doing business.

Preventing big crashes here is way much easier than dealing with devastating consequences. To find out more information about possible ways of mitigating your risks, you can subscribe to our free service -Important Compliance Updates from Central Asia - which regularly provides you with valuable insights and updates. It will keep you alert about you risks in Central Asia. – All you need to subscribe is simply to copy and paste this abbreviation “UFCA2” into the body of this message to us. - You will be immediately subscribed.

Phone: +1 800.207.5579

Email: cga@sarsenov-advisory.com

Assuring strength of your local Compliance and Ethics controls in Kazakhstan, Kyrgyzstan, Uzbekistan, Tajikistan, Turkmenistan

If your company’s businesses carried out in one of the Post-Soviet Central Asian countries like Kazakhstan, Kyrgyzstan, Uzbekistan, Tajikistan, Turkmenistan – then corruption and commercial bribes, frauds and money laundering – are the most insidious enemies for your program. They are developing like web viruses, never stop and never the same. The worst thing is that corruption and some other crimes become a normal way of life here. Corruption is getting worse year-after-year despite of many high profile Anti-Corruption, Anti-Money Laundering and other initiatives been taken regularly.

The number of cases charged by SEC and Ministry of Justice for corruption in Central Asia is increasing progressively. EBRD, World Bank and other international organizations has already recognized corruption and commercial bribes, as well as frauds and money laundering - to be the highest risk for this geographic zone. From this point of view Central Asia is the most Compliance risky zone, along with Eastern Europe and North Africa. So far, chargers by SEC includes millions of fines and even imprisonments of some U.S. managers. It might become too late when you learn that your local Compliance controls are punched by such malicious enemies in Central Asia as corruption, bribes, frauds and money-laundering.

When enemy is going to attack us, we always should be ready to counterattack. Defence mechanisms should stay on, and should be appropriate to the existing threats. But how can you be sure that your defence mechanisms on the ground in Central Asia are adequate to the posed local threats?

Why? If you are on the war you may be defeated not only because you were not able to detect location of your enemy and attack him appropriately. But also because your guns, shells, ammunition – your hardware might be not working properly. Identifying your most high impact risk and attacking them is not enough. Do you think it is worth to attack your enemy if you are not sure your hardware is tested, checked and certified appropriately? How often you test them? Would you like to test them more often and even double check in case of bad, dirty or damp conditions, where your ammunition might get broken down?

Would not you want to have firm assurance that everything works perfect before you fight the enemy? Central Asia is one of the most risky geographic zone in terms of corruption. You ammunition and arms should stay on ready-and-steady to be able guard and protect you any time. You local control mechanisms and the most risky locations protect your entire corporate compliance program, your corporation’s reputation, earnings, and your own career. Trying to fight dangerous enemy without your arms working properly is dangerous for you.

So saying that, who and how collects and provides you all that information you are using in monitoring and auditing your local businesses? How such information and what information is collected for monitoring? Who carries out your audits on the ground? How such information is provided to you? Can you be 100 percent sure that both people furnishing your questionnaires and interviewing other people, and those who provide them such information, are all doing precisely how it was supposed to be done by you?

Are you sure employees and third parties at your company’s most risky locations understand the right way all your messages you distribute to them? Do they understand your corporate policies and manuals properly? How can you be sure? Do they handle your corporate policies right in their each local contexts? Is your local compliance officer understood by local personnel? How could you learn that? Do local personnel and compliance officer understand seriousness of local threats as well as you do. How can you learn about that too? Are they on the ground able to separate the right signals from wrong signal like you would do that?

Do employees and third parties at your company’s most risky locations realize possible consequences of very small neglects in strict application of your corporate policies, codes, manuals, specifications and instructions? Can you be sure that local personnel, sales and marketing managers, vendors – understood what did you want to know from them during your last monitoring? Do they ask you questions? Do they disagree with you? How can you check whether your controls are adequate, stable and strong here?

The problem is that employees and managers of Central Asian offices might not let you know they disagree with you even on important issues, be it your company’s new policy, ethics rules, new methods, etc. It is inherent to most of Central Asian cultures to be polite, smile and not behave assertively towards foreign people and higher level managers. Your compliance manager and other stuff may not be raising issue to you when they are supposed to do that. You compliance officer lives in different ethics dimension, different reality, different vision. When your local manager looks agreeing with you, it does not necessarily mean he understands you or shares your vision. In Central Asia it is considered impolite when he or she disagrees with you being your subordinate. So you can be totally unaware of real picture and real circumstances about you compliance controls on the ground. You can only know what you are served by your local officer or managers. But stakes are high in Central Asia. You may find it out when it is too late.

Double checking your control systems and their proper working on the ground is always a good idea. But it becomes even more important when risks and possible consequences are disastrous. Cost of tiny deviations, small neglects and misunderstandings in the local compliance system’s work - when risks are high - will blow up all your compliance efforts.

In our everyday life we always want to double check before we do something serious. We even double checking our tickets and money every time before we flight. Is not preventing your company from severe penalties and shame (not to say about moral losses for you) a serious thing to care about? Is not strength of your local compliance system, working on the most dangerous geographic zone is something you want to be assured about?

Central Asia is one of the most dangerous and risky zone from Compliance risk point of view. It is hard to overvalue double checking local controlling mechanisms locally in Central Asia. You may compare this with mined area. You never know when something bad may happen, but you can check the strength of your controlling mechanisms and their proper working. Double checking them is the rule of game. You should do double checking of your controls working in the region if you seriously want to prevent catastrophic events.

The only problem to do that is time and budget constrains. While regulation burden and foreign corruption penalties are broadening, compliance budgets stay almost the same. You can not allow yourself to personally watch, test and try every control processes locally in every risky region of your company’s operation. And we totally understand it and what to help you to prevent bad things in Central Asia. Truly, you can not and you do not have to be at your every risky geographic location. But you have to know and see how things are going there. You want to have true picture of your compliance program’s working at most risky locations. You want to have spare view on controls in most risky areas - in addition to what you have been provided by you local compliance managers.

That is why we want to offer you to let us do that job on the ground. We carry out all that work for just a fraction of cost you may spend doing it yourself. We are always present on the ground in Central Asian countries. We do not have to spend time and resources to fly back and forth. You do not have to distract your attention from more strategic works. We can do one-time or periodic checks of your local compliance and ethics mechanisms working. And our prices are just a tiny fraction of what might be paid out as fines if you decided not doing it at all for Central Asian offices.

So how we can help you?

We can Evaluate your local compliance controls and develop Detailed recommendations for you on how to fortify your local compliance and ethics practices. We can spend as much time on the ground as it would be necessary until we get the real picture for you. We do not charge for time. Unlike law firms and many big consulting firms we only charge on-time limited price for the whole project. Unlike other consultants, we would be speaking local managers their local languages, and we would know how to present things from theirlocal culture point of view.

Depending on situation we can also develop Comprehensive recommendations on improving your local compliance and ethics components throughout the region, including describing entire business and cultural environment, identification of major risks, prioritizing them for your specific situation.

We can also help you to develop or revise your local Incentives program to your enhance your local compliance controls.


Phone: +1 800.207.5579

Email: cga@sarsenov-advisory.com



Targeted compliance trainings for employees at your Central Asian offices

Making your corporate ethics policies understood and routinely referred to by employees at you local offices in Kazakhstan, Kyrgyzstan, Uzbekistan, Tajikistan, Turkmenistan is a huge challenge. Solving this challenge means getting rid of foreign corruption exposure for those multinational corporations who have their offices in this region.

Targeted and culturally-customized Compliance Trainings and Consultations for managers, and employees, and third parties working in Kazakhstan, Kyrgyzstan, Uzbekistan, Tajikistan, Turkmenistan, would significantly reduce your exposure to foreign corruption and third party risks in Central Asia, and able to decline money laundering and local frauds exposure.

There is a huge cultural gap, and there is a lot of work that should be done to fill the gap, before your corporate ethics standards will start working in these Central Asian countries. If no such work done, no positive effect should be expected.

EBRD and World Bank ranks corruption among the top three obstacles to the business of a representative firms in most of Central Asian countries. The culture is so different even within this region. Also the very perception of “unethical” in these region is so different from that of in the U.S. or Europe in terms of misdeeds mentioned in most corporate Ethics Codes. This makes “unethical” widely tolerable at all levels of business and in society.

Many good Compliance programs stumble in this region only for this simple reason. They did not want to pay due attention to this very important factor. Actually, apart from the recent Pfizer’s case, there are many other examples of similar compliance failures, which are usually less known to the wider public.

The last thing any Chief Compliance Officer wants for him is total misunderstanding – which means NOT FOLLOWING - of his entire Compliance efforts. However, everyone knows that, unlike at headquarters, odds are too high that employees and managers at international offices, would pose a huge challenge for any strong Compliance Program. This becomes especially important when the main exposure to your program is foreign corruption. This challenge multiplies in case of Central Asia, where from 34 to 50 percent of population pay bribes (see Global Corruption Barometer 2013), and where third parties risk and money laundering risks are among the highest compliance risks.

Delivering trainings deeply customized for this culture and highly targeted for particular employees and local managers, and several liaisons in Central Asia, is the most wise and cost effective way to protect your program from the long term perspective. This is the only way to liquidate corruption exposure and mitigate other compliance risks for this region.

As a Compliance expert who is well familiar with both specifics on the ground and local languages in Central Asia, and, at the same time, at the cutting edge of all current international trends in corporate compliance, we have trained over 1,500 Compliance, Legal, Ethics, Internal Audit experts, managers and Board members across Central Asia.

We make Global Ethics Codes and Corporate Policies understood by employees and managers working in Central Asia. We know well what the local situation in the region is.

How we can help you?

So how we can help you? We can develop highly targeted and customized Trainings and Consultations for:

- Groups of local personnel (sales managers, marketing officers, other staff)

- Your local agents, consultants, vendors, suppliers, buyers

- Your local Compliance Officer in one of those countries: Kazakhstan, Kyrgyzstan, Uzbekistan, Tajikistan, Turkmenistan

All our trainings are highly customized to a particular company’s unique situation in the region. We take into account every specific moment, including particular location within the region, size of the company, type of business, number of employees, organizational structure, specifics of business model on the ground, use of agents and other third parties, and tones of other things. Every specific moment is important and might influence the approach we choose on how to get the job done in most successful and effective way.

Truly, it is not the easy job to try to change people’s view of things like ethics and business conducts. It is even harder to make them believe in it. But we chase the real results, that is why we are successful and we are trusted.

We can also develop and deliver Individual or in Group trainings for your managers at corporate headquarter who are dealing with businesses in Kazakhstan, Kyrgyzstan, Uzbekistan, Tajikistan, Turkmenistan.

In addition to all that we can develop Cmprehensive recommendations for you on improving your local compliance and ethics components in your Central Asian offices.

Phone: +1 800.207.5579

Email: cga@sarsenov-advisory.com



Adapting your compliance policies for Central Asia

In Post-Soviet countries of Kazakhstan, Kyrgyzstan, Uzbekistan, Tajikistan, Turkmenistan Local interpretation and adaptation of Global Corporate Ethics Codes and other Corporate Policies for Central Asia makes them live documents, which mollifies foreign corruption and third party risks, and significantly reduces money laundering and local frauds exposure.

We make Global Ethics Codes and Corporate Policies understood by employees and managers working in Central Asia. We deeply customize corporate policies and develop additional targeted manuals for Central Asia. We know well what the highest ethics and anti-corruption standards are, and we know well what the local situation in the region is.

How we can help you?

Here is what we can do to help you to strongly connect your corporate compliance programs to your offices in Kazakhstan, Kyrgyzstan, Uzbekistan, Tajikistan, Turkmenistan:

- We can customize and connect your Global Ethics Codes and Policies to a real situation on the ground, and provide appropriate trainings to your local staff. We guarantee 85 and higher percentage of understanding by local employees. We speak local languages and know local culture.

- We also can revise and align your existing local Compliance Ethics practices with your new or changed Compliance and Ethics policies with all appropriate adaptation.

- We can benchmark your existing local codes and policies against your Global Code and Policies. This is important when your company has just acquired new businesses here in the region.

- We can develop new local policies, manuals, specifications and other documents from the scratch to make them mostly effective. The newly developed policies and manuals will be strongly aligned with you corporate policies and will account all important local specifics.

- We can conduct benchmarking of your existing local codes and policies in countries of your operation against international standards of compliance, Federal Sentencing Guidelines for Organizations (FSGO), SEC' FCPA Guidance, OECD's Good Practices, etc. This is also important when your company has just acquired businesses here in the region.

Making your corporate ethics policies really understood and routinely referred to by employees at you local offices in Kazakhstan, Kyrgyzstan, Uzbekistan, Tajikistan, Turkmenistan is a huge challenge. Solving this challenge means getting rid of foreign corruption exposure for those multinational corporations who have their offices in this region.

We can also develop comprehensive recommendations on improving your local compliance and ethics components in your Central Asian offices.

Phone: +1 800.207.5579

Email: cga@sarsenov-advisory.com



Zooming in your compliance risk map: We help you to spot your killer-risks in Central Asia

According to KPMG’s 2013 analysis* Central Asia stands out from other regions showing the highest third-party risk. Central Asia is shown among three most dangerous geographical regions with the highest -70% - red reports in financial sector companies’ integrity due diligence.

EBRD ranks corruption among the top three obstacles to the business of a representative firms in most of Central Asian countries. According to EBRD’s 2010 Anti-Corruption Report, corruption is pervasive in several countries of Central Asia. Majority of respondents say they are either asked or are expected to pay bribes to receive public services.

With such a war zone on your Risk Map you are not expected to be shortsighted about your risks in countries like Kazakhstan, Kyrgyzstan, Uzbekistan, Tajikistan, Turkmenistan. Some risks may easily got under your identification radars. For this one of the most risky zones, Central Asia, you do not want to entrust all your compliance risk evaluation – or say your tranquility - to your local compliance/risk officer alone. You better be worried to secure a second opinion from independent expert who is very familiar with both highest Compliance U.S. and European standards, and with a real situation on the ground in countries like Kazakhstan, Kyrgyzstan, Uzbekistan, Tajikistan, Turkmenistan.

How we can help you?

We can develop your local risk map from the scratch. In case you are interested in total compliance risk picture in Central Asia we can develop Comprehensive report on your local Compliance Risks which will be tailored towards your specific industry and type of business in the region. We can also revise your existing risk map in its Central Asian part.

However, if your company is newly embarking to Central Asian markets and you are may be looking for initial understanding, getting familiar and delineating your local compliance risk universe, then we can develop a limited local risks inventory for your company’s specific operations in Kazakhstan, Kyrgyzstan, Uzbekistan, Tajikistan, Turkmenistan.

We can also help you in better classification or re-classification and prioritization of your all local compliance risks.

In addition to all that we can also develop comprehensive recommendations on improving your local compliance and ethics components in your Central Asian offices.

* KPMG. Astrus Insights. Analysis Of Third-Party Integrity Risks. 2013. Edition

Phone: +1 800.207.5579

Email: cga@sarsenov-advisory.com


Finding best candidates for your local compliance officer positions

We help you in finding best candidates for your local Compliance Officer positions in Kazakhstan, Kyrgyzstan, Uzbekistan, Tajikistan, Turkmenistan.

You would barely be able to have a peace of mind, having unqualified compliance officer on your rear - in the most risky geographic zone on your map. According to KPMG’s 2013 analysis* Central Asia is shown among three most dangerous geographical regions with the highest -70% - red reports in financial sector companies’ integrity due diligence. Same report says that Central Asia stands out from other regions showing the highest third-party risk. 53%(!) of all third-party reports by KPMG in Central Asia are red!).

EBRD ranks corruption among the top three obstacles to the business of a representative firms in most of Central Asian countries.

Taking the fact that we are very familiar with local realities, culture on the ground, and that we speak local languages, you may want to allow us to search for the best candidates for your local compliance officer position.

Local recruiting agencies would often be not fully understanding of what compliance is all about, and sometimes would even may barely get the idea of whom you are might be looking for. That is why we want to offer you our help.

We can handle that search job much more effectively. We will save you a lot of time and efforts, and protect from dealing with junk candidates. We can also better customize your job requirements to local circumstances than recruiting agencies would do that for you. All this means more effective search and, as a result, best candidate for your local compliance officer position. Best local compliance officer means better protection for you and your company.

We can assist you during your all interviewing of shortlisted candidates to help you sift out the best possible candidates with a right attitude for this job. We can also conduct full search by our own, including multiple interviewing process, presenting you final candidates only.

The better and more qualified your local compliance officer is, the better your compliance protection in this region. The better is your protection at this your risky regional office, the less chances that your Compliance program will be pierced unexpectedly. And finally, the better is protection of your Compliance Program, the better you sleep at night.

* KPMG. Astrus Insights. Analysis Of Third-Party Integrity Risks. 2013. Edition

Phone: +1 800.207.5579

Email: cga@sarsenov-advisory.com



Other Services

Third Party Risks

We can assist your office in doing third party due diligence locally within Central Asian countries, or we can conduct third party due diligence for you by our own.

Local investigations

We can assist you in your local investigations in Central Asian countries or we can conduct such investigations by our own.

Anti-Money Laundering

If you are a financial or other institution at which money laundering risk is one of the highest priorities, we can help you in identifying your specific risks exposure stemming from your company’s operations in Central Asia.

Customized reports

We can provide you customized reports on your local compliance and ethics controls, compliance and business environment, regulatory framework for your company business, compliance risks and other reports in respect of Kazakhstan, Kyrgyzstan, Uzbekistan, Tajikistan, Turkmenistan.

Other Solutions

If you want to discuss your particular situation related to the following countries: Kazakhstan, Kyrgyzstan, Uzbekistan, Tajikistan, Turkmenistan, please, feel free to email us a short description of your particular situation. We will be happy to discuss it with you.

Phone: +1 800.207.5579

Email: cga@sarsenov-advisory.com