Director | ALN Kenya | Anjarwalla & Khanna
ALN House, Eldama Ravine Close, Off Eldama Ravine Road, Westlands
P O Box 200-00606, Sarit Centre, Nairobi, Kenya
Telephone:+254 20 364 000 | +254 703 032 000
Willie is a Director at A&K and heads the law firm’s Forensics and Investigations department. He has over 25 years’ practical experience in forensic assignments covering various jurisdictions and industries and has successfully advised organisations in addressing complex matters on the risk of fraud, corruption and non-compliance in both private and public sectors. During the seven years prior to joining A&K, Willie headed up the forensic teams at two of the Big Four accounting and auditing firms where he had overall responsibility for developing the firms’ forensic offering across East Africa.
One of Willie’s passions is assisting organisations to implement financial crime strategies, policies and procedures that comply with required local and global regulations. He has a simple pragmatic approach of focusing on the facts, will hit the ground running and is known for his capability to effectively manage large and complex forensic assignments. He provides insight and advice during difficult and high pressure forensic incidents and brings global, local and cultural experience from working with leading global teams.
During his career, Willie has been involved in the growth and development of strong forensic teams with the skills, knowledge and experience to deliver a wide range of forensic services that include:
- Forensic investigations
- Fraud risk management
- Financial crime – AML/CTF/Sanctions/Fraud/Market
- Abuse/Insider Trading/ABC
- Ethics and compliance
- Corporate intelligence – Enhanced due diligence services
- Contract compliance
- Dispute advisory
- Forensic technology
- Crisis Management
- Association for Certified Fraud Examiners
2005: Bachelor of Laws (LLB), University of South Africa, SA
1996: National Diploma in Police Administration
Jun 2018 – Date: Director, Anjarwalla & Khanna
Jul 2015 – May 2018: Partner, Deloitte East Africa
Feb 2000 – Jul: 2015: Senior Manager, Associate Director and Partner, KPMG Forensic
Dec 1998 – Jan 2000: Inspector, Eastern Cape Gambling and Betting Board
Jan 1991 – Nov 1998: Detective Captain, South African Police Service
Before joining A&K Willie was involved in the following matters:
- Acting for a mid-tier bank in East Africa in connection with a special investigation into allegations of impropriety made in a whistle-blower report, including the review of several transactions with the aim of determining the veracity of allegations made.
- Acting for a leading insurance firm in East Africa in connection with a forensic investigation of its broker on boarding and commission payment process, including the assessment of the adequacy of internal controls during on-boarding agents and brokers, ascertaining whether commissions paid to brokers or agents were incurred in a proper manner, identifying conflicts of interest and assessing the extent of management involvement in the sourcing of clients, establishing whether there was infringement of the U.K Anti-Bribery and Corruption Act and the Foreign Corrupt Practices Act through bribes or kickbacks through its agent.
- Acting for a leading African airline operator in connection with a forensic audit to evaluate its system of internal controls, including conducting a review of financial systems and statements, quantification and assessment of loss and reporting, digital forensics and analyzing electronic devices using key word searches to corroborate key information for the investigation and providing advice on strengthening the corporate governance & internal control environment for firm implementation.
- Acting for a leading International bank in connection with a regulatory investigation into certain international trade transaction, including the validation of transactions that were allegedly part of a potential money laundering and/or terrorist financing scheme and providing recommendations on process improvements and remedial actions.
- Acting for a distributor of a leading US mining company to conduct a FCPA review, including conducting the general assessment of the processes at various operations in Africa, detailed transaction testing and assessments on all the high risk countries and business areas.
- Acting for a leading oil company with presence in Kenya and Uganda in connection with a forensic audit conducted over stock discrepancies, including a detailed analysis of the affected stocks, a quantification exercise to determine the resultant financial loss incurred an assessment of the internal controls to establish any weaknesses that had been exploited and provide recommendations to remediate control gaps.
- Acting for a pan-African housing agency in connection with a forensic audit, including the investigation of manipulation of financial statements by restructuring non-performing loans and funds misappropriation.
- Acting for a health department in provincial Government in connection with an investigation of alleged misappropriation of USD 13 million of government aid funds intended for child feeding schemes, including recommending disciplinary action against fraudulent senior officials.
- Acting for a large entertainment company in Europe in connection with a forensic investigation into the manipulation of financial systems and fraudulent transactions.
- Acting for a housing company in Europe in connection with an investigation into the misappropriation of the assets of the company by its former directors.
- Acting for an international construction and engineering company with operations in Mozambique in connection with an investigation into fraud and theft by the company director accused of misusing and mismanaged projects.
- Acting for a mining company in South Africa in connection an investigation into the misappropriation of the assets of the company by its former directors and employees, including a review of the local and off-shore structures created by the former directors and employees, fraudulent financial reporting, possible contraventions of exchange control regulations and background checks of consultants used by the former directors and employees. In addition, assisting the current directors with a mediation process in respect of a substantial claim.
- Acting for a transport sector in South Africa in connection with the investigation of corruption in respect of subsidies provided by the Government to local bus operators with specific focus on the extensions of the contracts by individuals in the department – kick backs.
- Acting for a large bus company in South Africa in connection with the investigation into certain suppliers of the company, including allegations of collusion with company employees, fraud and kickbacks.
- Acting for a trade union in South Africa in connection with an investigation into fraudulent actions by senior trade union representatives during the distribution of funds to workers, including a larger investigation of 6 firms of attorneys who administered funds on behalf of the trade union.
Forensic Advisory and Compliance
- Acting for a large UK insurance company in connection with the implementation of a group-wide Anti-Bribery Corruption programme, including the assessment of “ABC readiness” across all service lines and countries to establish compliance with the new UK Bribery Act (2010).
- Acting in a confidential engagement undertaken under legal privilege covering the identification of “Introducers” within a large international Bank of Kenya, Tanzania and Uganda, including assessing the elements of Anti-Bribery and Corruption for the Introducers identified.
- Acting for a listed manufacturing company in Kenya in connection with the Fraud Risk Management strategy and framework review, including the alignment of their current structure to industry best practice, identification of business processes most vulnerable to internal and external fraud, an assessment of internal controls, the development of a plan to mitigate vulnerabilities where gaps were identified and to improve communication and awareness about fraud across the organisation.
- Acting for a company in connection with a review of the Fraud, Bribery and Corruption Risk Management framework with an aim to successfully create an environment, including conducting a fraud and corruption risks assessment, assessing the existing fraud and corruption framework by performing a GAP analysis between the current environment against best practice, designing a fraud and corruption framework in-line with best practice relevant to the organization and evaluating current controls to prevent, detect and respond to the risk and compare with leading practice.
- Acting for a Pan-African insurance firm in connection with a Financial Crime framework assessment for Anti-Money Laundering & Combating Financing of Terrorism (AML/CFT), including a review of AML / CFT process flow, specifically the current risk based approach, customer on-boarding, customer due diligence, enhanced due diligence and on-going due diligence, customer screening involving sanctions and politically exposed persons, transaction and activity monitoring, cash threshold reporting and suspicious transaction / activity reporting, and training on culture and awareness session covering strategy, oversight, governance and compliance.
- Acting for a financial services company, in connection with a review of the anti-fraud framework, including a GAP analysis on the current strategy on internal and external fraud risk management, the design of a new Fraud Risk Management framework and a new governance structure.
- Acting with various teams across East Africa and Mauritius in conducting an assessment of a large number of customer accounts for a large multinational financial institution, including determining whether the customer files were compliant to the financial institutions group KYC policies, procedures and local AML laws and regulations in the three countries.
- Acting for one of the largest financial institutions in Kenya to undertake an AML conformance review including, conducting AML governance training, monitoring AML controls and identifying gaps/deficiencies in the control structure.
- Acting for various companies in Africa in connection with KYC remediation, investigations and reporting of suspicious activity reporting related to AML system, developing a KYC tool to automatically detect compliance with in-country regulations, enhanced due diligence for PEPs in two of Tanzania’s financial institutions, developing an AML/CFT online training tool for a regional insurance company, performing various PEP reviews (consisting of financial analysis and customer due diligence, conducting AML/CFT Board trainings to various financial institutions within East Africa and conducting gap analyses for financial institutions and updating the policies thereafter.
- Acting for an international bank in a benchmarking exercise, including assessing its existing forensic services’ mission, strategy, governance framework and its major internal business to enhance the existing forensic capacity to match best practice, in order to enhance its forensic capacity.
Forensic Due Diligence
- Advising an international bank based in East Africa in connection with a due diligence review of the transaction processing of their target firm, including a comprehensive review of the target’s Anti-Bribery and Corruption policy, the AML/CFT framework and the Foreign Account Tax Compliance Act (FATCA) compliance, the scope of the due diligence elements under review and the end-to-end Financial Crime processes and procedures. The AML review entailed transaction and account monitoring, correspondent banking and customer on-boarding and the FATCA Standard Operating Procedures and Policies were reviewed in line with the existing registration, communication and reporting procedures.
- Advising a large bank in connection with an ABC pre-acquisition due diligence to identify and quantify all matters that may impact on the offer price for the bank, including gap analysis reporting of Anti-Bribery Corruption policies & practices applied by targeted bank minimum standards that would cause serious risk to the acquisition or prevent the transaction from closing.
- Acting in over 80 corporate intelligence assignments for various organizations across Africa including, performing background searches on individuals and entities, researching publicly available information, human source intelligence and relationship mapping.
Training and Events
- Training and presenting in events on various topics, including forensic investigations, building effective compliance programs, fraud risk management, data analytics and anti-bribery and corruption.
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