Jonathan MarksEd. Note-I continue my series of blog posts on thought leaders in the compliance space today with an interview of Jonathan Marks, a Managing Director at Navigant

  1. Where did you grow up?

I was born in New York City, raised in the Bronx, and moved to Bucks County, Pennsylvania where I live today with my family.

  1. Where did you go to college, what did you study and how did it influence your career going forward?

I am a proud graduate of Bloomsburg University of Philadelphia, where I studied accounting.

I was hired by Coopers & Lybrand (Philadelphia Office) in my junior year of college, and joined the audit practice where I was exposed to fraud and misconduct cases. Audits were like giant puzzles to me, and I love puzzles, but I also love reading people and their behavior. The psychology of people and what makes them commit fraud is a fascinating topic.

  1. How did your work lead to your current expertise on the FCPA and anti-corruption compliance?

Back in the 1990’s I worked on a global fraud risk assessment for a company and identified the lack of control over various expenses. This led to a review of business practices in the U.S. The results were, not surprisingly, very revealing and I was asked to work with in-house counsel on assessing risk globally. At that time, the FCPA Act was not high profile as it is today. I had a suspicion that FCPA issues were lurking within many organizations, and I began to advise my clients more proactively about corruption issues. My experience showed me that an organization couldn’t possibly build an effective compliance program without first having a good governance framework and a thorough global fraud risk assessment that extended beyond the enterprise. I eventually developed a FCPA Compliance Action Plan and began to use the plan to help my clients build or assess their compliance programs.

  1. You have long been active in the IIA and ACFE, both locally and nationally. What have your roles been, and how has that been an adjunct to your practice?

I love giving back to the profession! A few years ago, I served as the President of the Philadelphia Chapter of the IIA, and I currently serve on the Board in various capacities. I also serve on the faculty of the ACFE, and have taught and spoken at numerous conferences and chapter events.

Interacting with professionals who share my passion for investigating and fighting against fraud enable me to share diverse perspectives with my clients. I am always challenged to rethink my beliefs and methodologies in order to provide my clients with the most innovative and practical approaches to mitigating their risk to fraud and to other potential issues.

  1. What are some of the common mistakes that you still see from an internal controls/internal auditing in the FCPA/anti-corruption space?

Most company executives still don’t understand the waterfall model or sequential design process of governance, risk and compliance. Moreover, the fraud risk assessments I have reviewed for multinational companies are generally not thorough or do not adequately address corruption! It is so important for companies to understand that by investing a little time into their compliance programs, they can save themselves a lot of headaches down the road.

There is a real opportunity for companies to up their game with respect to designing effective internal controls. The Internal Audit function should conduct regular testing of higher-risk compliance-sensitive accounts, using technology to mine data and perform analytics.

  1. You have consistently talked about a best practices compliance program as having both a prevention and detection function. Do you find that message is resonating more with companies?

I think most companies want to believe, or talk themselves into believing, that their compliance programs are best in class and include a preventive and detective component. In reality, that’s not the case. I call this “perfect place” syndrome. Others or the realists know they are far from best in class, but have identified gaps in their program and have put a plan in place to remediate those gaps and enhance compliance throughout the organization.

  1. You recently moved to Navigant, what do you hope to accomplish professionally with this move?

I am thankful for every opportunity I have been given professionally. Navigant experts have deep industry knowledge across Financial Services, Healthcare, Energy, and Construction and the requisite expertise to enable companies to defend, protect and create value. I belong to a team of dynamic forensic accountants, compliance professionals, and litigation experts who are adept at tackling today’s most complex accounting, legal and regulatory issues. My goal is to bring companies multifaceted solutions to their most critical compliance and legal challenges.

Jonathan Marks can be reached at