Paul Otonglo

Paul Otonglo

Senior Manager | ALN Kenya | Anjarwalla & Khanna

Physical Address:

ALN House, Eldama Ravine Close, Off Eldama Ravine Road, Westlands

Postal Address:

P O Box 200-00606, Sarit Centre, Nairobi, Kenya

Telephone:

+254 (0) 20 364 0000

Email Address:

  1. Background

    Paul is a Senior Manager at A&K’s Forensics and Investigations department. He has over 10 years’ extensive experience in financial consultancy. Paul has been involved in forensic investigations, dispute advisory projects, corporate restructuring engagements and internal audit reviews. He also has wide ranging experience in fraud investigation, having been the project lead on matters that included:

    • The review of procurement matters
    • Asset and cash misappropriation
    • Loss quantification
    • Employee misconduct
    • Fraud risk analysis
    • Corruption/ethical environment assessment
    • Enhanced due diligence and dispute advisory engagements
  2. Professional Membership
    • Association for Certified Fraud Examiners
  3. Professional Qualifications

    2019: Master of Commerce (Forensic Accounting), Strathmore University, Ongoing

    2006: Certified Public Accountant of Kenya – CPA(K)

    2008: Bachelor of Commerce (Finance), Catholic University of Eastern Africa 

  4. Career Summary

    Apr 2022 – Date: Senior Manager, Anjarwalla & Khanna -Forensic, Risk & Compliance

    Jan 2019 – Mar 2022: Manager, Anjarwalla & Khanna – Forensic, Risk & Compliance

    Jan 2015 – Dec 2018: Manager-Risk Consulting, KPMG Forensic

    Sept 2012 – Dec 2014: Assistant Manager-Fraud Investigation & Dispute Services, EY

    Mar 2011 – Feb 2012: Consultant-Internal Audit, Protiviti Middle East

    Sept 2008 – Feb 2011: Associate-Risk Consulting, KPMG Forensic

  5. Top Matters

    Claim Computation and Evaluation

    Prior to joining A&K:

    • Acting for an insurance claimant in connection with the computation of the amount due from an insurance company following loss of production machinery, evaluating the claimant’s and insurance company’s obligations based on the policy, actions following the loss of insured assets and computing the amount due from the insurance company in this matter.
    • Acting for a government parastatal in connection with the determination of the amount due to a third party in an arbitration matter, including evaluating the reasons for non-performance and financial amount assessed to be payable following the termination of contract. The client had been sued by an international company for failing to abide by a joint venture agreement. Acting for a commercial entity in connection with their preparation of a claim for lost business following a delay in shipment arising out of disruption due to civil disorder, including assessing the client’s claim in circumstances where imported goods expired due to disruptions during shipment. The client sought accounting support to compute the amount assessable as being due in the matter.
    • Acting for an insurance company in connection with the assessment of the amount payable under a policy issued to a bank, including evaluating the amount under the claim that could justifiably be paid based on the policy provisions. The client received a claim for settlement of a substantial amount following fraud at the bank.
    • Acting for an agro-producer in connection with the evaluation of the net amount due in a matter where the client and their suppliers contested a long running debt and sought arbitration, including evaluating the amount due based on the commercial relationship between the parties and evaluating evidence supporting this amount.
    • Acting for an international oil marketing company in connection with the assessment of the status of adherence to distribution contracts, including gathering evidence of non-compliance, establishing the persons involved in negotiating the contracts, monitoring performance and quantifying the amount over-paid to vendors contrary to the contracts in place.
    • Acting for a Rwandan bank in connection with the assessment of the state of compliance to agreements in place during the client’s buy-out of a Rwandan microfinance organisation, including determining whether the agreed amount of finance was invested and evaluating potential penalties due to a delay in meeting the contractual terms. 

    Forensic Investigation

    • Acting for a development agency in Tanzania in connection with an investigation into a health sector disbursement it made, including carrying out a financial verification of the accounting statements presented during this project, reviewing of procurement, reconciling of reported expenditure, confirming of the circumstances under which emergency expenditure was reported and reviewing of staff payment records.
    • Acting for a South Africa-based investment venture in connection with the review of a prominent Tanzanian hotel, including carrying out a verification of the reported net earnings of the hotel, identifying of the fraud risks faced by this venture and providing recommendations on mitigating the same.
    • Acting for a government agency in connection with the establishment of its land holdings due to uncertainty of the status of parcels it had held since its establishment, including investigating the status of the client’s landholding and verifying the circumstances of acquisition and disposal of any parcels of land held over several decades.
    • Acting for an insurance company to evaluate fraud risks in connection with its claim processing activities, including analysing the fraud risks, reviewing the claim registration and settlement process and carrying out an investigation into potential collusion and reviewing a sample of paid claims.
    • Acting for an agricultural processing firm in Kenya in connection with a forensic investigation of suspected fraud rebates processed in the company, including conducting an analysis of the circumstances under which rebates were issued to clients, the culpability of employees and a fraud-risk analysis of the payment processes.
    • Acting for a saving and lending organisation in Kenya in connection with a fraud investigation on financial misreporting and misconduct by the previous management, including conducting an analysis of bank reconciliations, reviewing of loan conditions, reviewing of IT systems and changeover analysis.
    • Acting for a large private hospital in Kenya in connection with a forensic investigation into its procurement practises, including a conducting a general fraud review covering its procurement process, financial operations and information technology system status and reporting on fraud loopholes in procurement procedures.
    • Acting for a bank in Tanzania in connection with a misconduct investigation into misuse of bank ATMs, including the conducting an analysis and quantification of the amount that could not be accounted for, collecting and collation of exhibits to support a criminal case against the suspects and reporting on operational weaknesses observed in the relevant bank operations.
    • Acting for a FMCG distributor in Kenya in connection with a fraud investigation into suspected cash misappropriation, including analysing suspected manipulation of accounting records to conceal the misuse of cash received from customers, interviewing of the suspects’ colleagues and the preparation of a report to support a criminal case against the suspects.
    • Acting for a consumer products manufacturer in Kenya in connection with an investigation into unaccounted stock loss of the consumer products, including a reviewing of the production, storage and release of products at this manufacturer following the discovery of its unbranded material in the local market. The investigation revealed misuse of expired stock, quantified the unaccounted stock and reported on system weaknesses in the production chain of the client.
    • Acting for a County Government in Kenya in connection with an investigation of County Government employee documents, including reviewing of its staff following suspicions about the existence of “ghost workers, registering and interviewing of workers in liaison with the National Registration Bureau to authenticate, identity and analysing of staff files to verify payments made to employees.
    • Acting for a manufacturing firm in Kenya in connection with an investigation into suspected financial statement misrepresentation, including the analysis of the transactions processed by a former employee and review of the applicable transactions processed by the suspect to determine the effect of misreporting.
    • Acting for the Government of Rwanda in connection with an investigation into joint venture transactions by the Government and a foreign investor, including reviewing of the accounts of the joint venture to establish the circumstances under which dividends were not forthcoming under the terms of the joint venture, investigating sample financial records of an asset which was managed under the joint venture, and advising the client about the options for termination of the joint venture and the financial effect of each option.
    • Acting for a bottling company in Kenya in connection with an investigation into staff misconduct, including conducting an investigation of the procurement process at this client, selection of the customs clearing agent, an investigation into allegations made by a whistle-blower, analysis of the records maintained, quantification of the under-declaration of commodities for tax purposes and reporting on the recruitment of key personnel to the client.
    • Acting for a Ugandan logistics firm in connection with an investigation into employee misconduct, including a reviewing of recruitment policies and staff practices involving the selection of personnel and practices constituting misconduct.
    • Acting for an international aid agency’s Somalia operations in connection with the analysis of expenses, including reviewing of the financial records maintained by an intermediary based in Somalia to identify and quantify suspicious payments.
    • Acting for a multi-donor NGO in Uganda in connection with a forensic review of the activities of 11 of their Implementing Partners (IPs) following allegations of embezzlement of project funds, fictitious transactions, kickbacks and forgery of documents, including conducting desktop reviews of IP accountabilities, reviewing of expenditure documentation, conducting site visits to ascertain beneficiary existence, conducting interviews with the IP management teams with the aim of gaining an understanding of their operations, obtaining additional documents from the IPs and reporting on the findings.
    • Acting for an NGO in Uganda in connection with fraud investigation into misuse of cash disbursements, including conducting process walkthroughs; reviewing of bank statements and corresponding authorization documents; reviewing of petty cash document and transactions and third party verifications to ascertain credibility of support documentation, and conducting a review of the controls.
    • Acting for a mobile telephone services operator in Kenya in connection with online searches, media searches and coordination of company searches with the aim of identifying related party transactions, including reviewing of procurement processes, the appointment of vendors and how they are managed and conducting due diligence on suppliers –.Acting for a Rwandan construction consortium in connection with the review of project performance issues, including conducting an investigation into the activities of members of the project implementation team, evaluating of cash-flows throughout the project’s life as compared to construction progress and making recommendations on timely corrective actions to keep implementation on plan and avoid wastage.

     Forensic Due Diligence

    • Acting for a local bank in connection with the verification of education and employment history, including reviewing and verifying of claimed academic and employment credentials of more than 500 employees at a local bank.
    • Acting for a foreign embassy in Tanzania in connection with a diligence review of three suppliers based in Tanzania, India and Dubai who were shortlisted following a tender evaluation process.
    • Acting for an organisation in Kenya in connection with a due diligence review on a potential partner in a business venture for the client, including performing detailed internet searches on the partner on negative media checks, background confirmation, business relations and associations, litigation history, sanction checks and other relevant publicly available information.
    • Acting for a foreign embassy in Tanzania in connection with a supplier due diligence review on a tender issued for the supply of education material, including the performing background checks on each of the vendors, their shareholders and directors, litigation history checks, reference checks, media and adverse media checks, sanction checks and site visits to verify existence of the business.
    • Acting for an organisation in Kenya in connection with a pre-employment due diligence review, including performing a background check on a high-level potential employee of an organisation to determine whether there was any information relating to potentially unethical practices based on previous employment.
    • Acting for a financial institution in Kenya in connection with a due diligence review on the client’s significant debtor, including determining the organization’s location, ownership, management and operations, conducting registration check, making site visit to the registered location, contacting previous employees and legal team and media checks on the subject of the review.
    • Acting for a mobile telecommunications company in connection with the review of multiple suspected cases of fraud and misconduct carried out by employees and third parties, including investigating cases of bribery and corruption, sexual harassment, procurement fraud and asset misappropriation.

    Due Diligence

    • Acting for an American client in connection with a review of the claimed existence, capacity and operations of a Kenyan firm and its Sudanese affiliate.
    • Acting for an investment company based in Dubai in connection with a background check on its Ethiopian business partners, including conducting a due diligence review of Ethiopian associates of the Middle Eastern based entity to verify their existence, location and capacity; and also to validate their profile.
    • Acting for a Kenya-based international NGO in connection with a background check on its affiliates in South Africa, including conducting a due diligence review of South African associates of a local entity to verify their existence, location and capacity; and also to validate their profile. 

     Compliance/Internal Audit

    • Acting for an agricultural processing firm in connection with the carrying out of a review of key processes at the firm, including reviewing several processes at this firm as part of the internal audit function to provide assurance to the directors on the state of the internal control system.
    • Acting for a global logistics firm in connection with the carrying out of a risk mapping at the firm, including evaluating the status of risks at this entity as part of preliminary activities guiding the internal audit plan, reviewing of policies, observing the processes and conducting interviews with key personnel.
    • Acting for a mobile telecommunications company in connection with the carrying out of a review of the finance and accounting processes at a mobile telecommunications company, including carrying out reviews of key processes at this firm as part of the internal audit function to provide assurance to the directors on the state of the internal control system.
    • Acting fora development agency to assess risks involved in the prospective winding up of its operations in Tanzania, including assessing the state of affairs of the client, providing recommendations on its winding up, and preparing a schedule of activities to guide the winding up of the firm.
    • Acting for an international insurance company in connection with  the evaluation of its operations and prepare an approach to guide the dissolution of its Ugandan business, including assessing the state of affairs at this entity, providing recommendations for its winding up, and preparing a schedule of activities to guide the winding up of the firm. 

    Fraud Risk Management

    • Acting on behalf of a large Savings and Credit organisation in connection with evaluation of its overall control environment with a focus on fraud risks, including mitigating of existing and potential fraud risks following the client experiencing a series of frauds through which it suffered losses, and reviewing of overall governance, roles, internal controls, processes and technology.
    • Acting for an international NGO in carrying out a review of fraud risks at its Ugandan office, including identifying governance issues and control weaknesses in the target’s operations, through a review of processes, interviews and document review to evaluate the extent of mitigation of fraud risks and providing recommendations on improving the control environment.
    • Acting for an international agro-producer’s Kenyan office in connection with an engagement that included evaluation of the anti-fraud policies and efforts and provision of recommendations on mitigating identified issues.
    • Providing training to a multinational agro-processing firm in connection with counter-fraud strategies to be used as part of its fraud risk management.
    • Providing a week’s training during a forum on fraud risk management in Uganda that focused on common fraud types in East Africa and strategies for countering the same.
    • Acting as a senior trainer during month-long capacity building on behalf of a government agency on ethics, fraud and technology to senior, mid and entry level employees at a government agency.
    • Acting for a local commercial bank in connection with the bank facing regulator sanctions arising out of the bank handling money from questionable sources, including a week-long training on ethics and compliance.
    • Acting for several clients in connection with whistleblowing matters, including providing training aimed at establishing a common understanding of whistleblowing and explanation of how the reporting mechanism works as well as building confidence in the whistleblowing mechanism.
    • Acting for several client in connection with their implementation of whistleblowing platforms, including designing and reviewing whistleblowing policies, conducting training sessions and overseeing reporting of complaints to designated recipients. 

    Anti Money Laundering

    • Acting for a bank in Rwanda, a regional and local bank based in Kenya, and two top tier banks in Ethiopia in connection with their capacity building, including training executive and operational management on anti-money laundering, evaluating the guiding technical material and national and corporate regulations, assessing the aspects important to trainees, and preparing and presenting of training material.
    • Acting for a leading bank in Rwanda in connection with AML compliance assessment to evaluate the state of adherence to banking regulations, including conducting an assessment of the effectiveness of existing AML policy to cater for money laundering risks and assessing adequacy of documentation for Know-Your-Customer (KYC), Know-Your-Process (KYP) and Know-Your-Transaction (KYT) aspects of AML. 

    Anti Bribery and Corruption

    • Acting on behalf of a South African company in connection with a matter where its local subsidiary was suspected of involvement in corrupt acts to secure business, including conducting investigations into suspected bribery and corruption by a local company, involving seizure and analysis of documents, imaging of computers and other electronic devices and interviewing of both staff and third parties.
    • Acting for a US pharmaceutical products distributor in connection with compliance of Kenyan anti-bribery law by its local partners, including explaining the relevant laws and organisational policies, interviewing key personnel in the organisations on their operations to identifying corruption risks and testing a sample of transactions to identify compliance violations.
    • Acting for a British pharmaceutical products distributor in connection with advice on risks in several country operations in East and Southern Africa, including developing an understanding of the country operating environments through interviews and review of policies, evaluating the extent of compliance through review of transaction documents and preparing of the engagement report.
    • Acting for a prospective US investor in Kenya and Sudan, in connection with the evaluation of anti-bribery and corruption risks as part of a due diligence review prior to investing in the two countries, including assessing of applicable regulations, reviewing of the companies’ operating models and reviewing of a sample of accounting records to identify potential violations.
    • Acting for a logistical company in connection with the review of their operations in Kenya and Uganda where the client sought advice on the state of compliance in place by its offices in Kenya and Uganda based on its parent company’s and local policies, including reviewing of transaction documents and interviews of key staff and external contractors.
    • Acting for a bank in Rwanda in connection with the evaluation of corruption risks on behalf of a potential South African investor, including assessing of applicable policies (South African and Rwandan), interviewing of staff and external parties and reviewing a sample of transaction documents to identify any violations.
    • Acting for a Bank in Tanzania in connection with the identification of any violations relating to bribery and corruption in anticipation of review by the country’s regulator, including identifying of risks arising in the client’s operating environment and reviewing of high risk transactions to identify non-compliance. 

    Training and Events

    • Presentation to the Institute of Certified Public Accountants of Kenya on Anti-Money Laundering regulations and procedures.
    • Presentations to the Institute of Internal Auditors (Kenyan Chapter) on the effectiveness of Whistleblowing mechanisms, evidence and prosecution of economic crimes.
    • Presentation on insurance fraud risks during the first Kenya insurance/consultancy firms forum in Nairobi.
    • Presentation to the Institute of Internal Auditors (Kenyan Chapter) on Fraud Detection during routine audits and investigation procedures during Internal Audits.
    • Presentation on enhanced due diligence to the Oil & Gas forum invitees during the 2016 Kenya Oil & Gas forum.

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