The issues around shell companies continue to bedevil national governments, state governments, anti-money laundering regulators and prosecutors and commercial businesses. They continue to be a problem for anti-corruption compliance programs as well. Such programs appropriately place most of their focus on the “how” of bribery and corruption, but shell companies remind that there is a “who” component to be managed. That “who” component was highlighted once again by Ryan Hubbs, global anticorruption and fraud manager for Schlumberger and one of the thought leaders around unmasking shell companies.
