Owner
Alfred Spencer III
Founder, AS3 Compliance - Software · Munich
I help compliance leaders see clearly how their anti-corruption program is doing, and what to fix first.
Alfred has spent more than 20 years in executive compliance roles in international companies. He served as Chief Compliance Officer for Progressive Leasing, Fujitsu, BSH and GE Vendor Financial Services. For Fujitsu he also served as Chief Risk and Audit Officer. During VEON’s monitorship he led Internal Reporting and Investigations.
His work has included anti-corruption programs: building them, testing them, and explaining them to boards and authorities. He holds a JD from the University of Texas.
Why the assessment
Compliance leaders are often asked a simple question by their board or their lawyers: “How strong is our program?” Alfred built the AS3 Compliance Program Assessment to make the answer clear, and easy to show. The assessment is based on the U.S. Department of Justice’s Evaluation of Corporate Compliance Programs. Its anti-corruption module is keyed to the FCPA Resource Guide and mapped to ISO 37001.
Focus areas
- FCPA and anti-corruption programs
- Third-party due diligence and oversight
- Reporting to senior management and the board