Robert J. Ward, Jr. is an anti-corruption, transparency, international taxation, global trade and customs consultant and a recognized expert for implementing state of the art compliance programs in companies scaling the world in their business operations. He studied political science and French at America’s premier Catholic University, the University of Notre Dame near Chicago earning a Bachelor of Arts in 1984. He studied comparative law at Tulane Law School in New Orleans, having studied law at the Universitaet Regensburg, Germany for one year on a DAAD scholarship, and ultimately earned a Juris Doctorate in 1987. In 2001, Robert also obtained an LL.M. (Master of Laws) degree in international taxation at the University of Houston Law Center. Robert is an American citizen who has travelled globally and is fluent in English (native language) and German with a working knowledge of Spanish and French as well as basic exposure to Mandarin Chinese.
Robert has more than 30 years of experience providing legal services in law firms, big-four
international consulting firms as well as in some of Houston’s most dynamic companies. Some of Robert’s more notable positions have included serving as the Chief Compliance Officer for RigNet, Inc., voted the most entrepreneurial company for 2014 in Houston (Ernst & Young, June 2014). He has served as the corporate compliance officer for the world’s largest maritime services company, Wilhelmsen Ships Service, with some 2,400 offices globally in more than 175 different countries. This latter opportunity permitted Robert world-wide travel of more than 50% over a three-year period. Robert has also experienced the dire consequences of compliance failures having worked for both Arthur Anderson LLP and Enron International. The fallout from these two-latter fatal corporate ethics failures gave impetus to Robert’s focus on compliance and remediation strategies as a career.
Respecting Robert’s work in anti-corruption and transparency issues, he has been tasked with establishing compliance systems for the prevention of violations of the U.S. Foreign Corrupt Practices Act (FCPA) and, as of 2010, the UK Bribery Act as well. Absent transparency in governmental and private sectors, the benefits of a free market economy system quickly erode and collapse under a wave of corruption scandals. The U.S. Department of Justice and Securities and Exchange Commission have built up an ominous reputation for strict enforcement over the past decade of the FCPA. Because well over 90% of corruption violations occur through dealings with third-party vendors and sales agents, Robert has concentrated his efforts recently on third-party vendor and sales agent due diligence as a critical link in the compliance program chain.
Robert also is keenly concentrated on Office of Foreign Asset Control (“OFAC’) Sanctions and Embargo developments. While at Wilhelmsen, he worked with outside counsel in setting up a global sanctions and embargoes compliance program which spared the company from a potential bankruptcy reorganization filing. The latter almost became necessary after a subsidiary of the company was cited for an OFAC violation just months before Robert started work there. All U.S. dollar clearing house banks in New York City initially required protracted due diligence checks prior to completing wire transfers for the company. This significantly disrupted the company’s cash-flow before Robert was able to convince the banks of the soundness and reliability of the company’s OFAC compliance program. Robert also spearheaded a global investigative effort while at RigNet that involved sanctions violations ultimately disclosed to OFACand the U.S. Department of Justice. Justice fortunately declined to prosecute, noting the rogue employees acted alone and giving the company significant credit for its effective compliance program.
Finally, Robert was fortunate to participate as a team member in Rotary International’s first young professional trip to East Germany after the Berlin wall came down in the early nineties. In addition, Bob has served in the Federal Bar Association as well as in the Houston Bar Association’s International Law Section, having held positions of secretary, treasurer, vice president, president and executive council member in both those organizations. He is currently an active member in the Associate of Corporate Counsel as well as the Association of Certified Fraud Examiners, and he focuses on compliance issues through participating in compliance blogs where best practices are frequently discussed.
Two recent OFAC enforcement actions underscore the importance of screening the IP address of a customer to ensure an embargoed country is not at issue.read more
This post describes the importance of proper “fuzzy logic” capabilities in screening software through review of two prominent OFAC cases: Apple (2019) & Amazon (2020).read more
OFAC provides two procedures for making a request for delisting based on mistaken identity or changed circumstances – requesting an in-person meeting with OFAC with competent counsel is a must.read more