Michael Comer: Managing Director

Mike Comer served as a Commissioned Officer in HM Customs & Excise Investigation Branch where he successfully handled hundreds of investigations into commercial, revenue, narcotics smuggling, organised crime and complex financial frauds. He investigated some of the first cases of computer crime in Europe. He has multiple commendations from Judges at the Central Criminal Court, Old Bailey and from other civil and criminal courts throughout the world for his skills as an investigator.

Headhunted by Esso Petroleum Company Limited, he was appointed as Corporate Security Co-ordinator and later as Security Adviser for Esso Europe Inc. He directed the European-wide protection programme for critical assets including investments in the North Sea, refineries, extensive computer and communications networks, a large marine fleet, thousands of retail outlets and for more than 60,000 people.

In 1979, he resigned from Esso to found Network Security Management Limited which (as a subsidiary of Hambros Bank Limited) arguably became the most successful fraud consultancy in Europe.  In 1996, he resigned from Network and launched Maxima Group plc. which established itself as a leading counter- fraud practitioner.

However, in both Network and Maxima, he became disillusioned over the inability of these, and other large consultancies, to consistently maintain quality and to deliver value to Clients. But also, as the companies grew, Comer’s job became exclusively administrative, removing him from his passion for working on assignments. In 2002 he resigned from Maxima and founded Cobasco Group Limited3 to work with a small circle of Clients.

Comer has worked with hundreds of Clients on a wide range of preventive assignments and has investigated hundreds of high profile frauds in Europe, Asia, Africa and in South and North America, successfully and mainly without publicity. In 1974, he invented the methodology of Critical Point Auditing based on automated tests and diagnostic profiling which has, so far, uncovered losses in excess of $300,000,000.

He worked with Edward de Bono and James Martin on a strategic project to reappraise the way businesses manage operational risks and with George Carman, QC on assignments and on a ground-breaking programme on interviewing and cross-examination.

Comer lectures in Europe, Asia, Africa, South America and the United States to professional audiences including senior managers, accountants, internal auditors, to professional associations London and City University Business Schools, Harvard Advanced management groups, Stanford University and to the legal profession.

He served as Visiting Professor at Cranfield Institute of Technology and as Honorary Visiting Fellow at the Scarman Centre, University of Leicester. He is past President of the European Chapter of the Association of Certified Fraud Examiners and ex-Chairman of the American Society of Industrial Security’s Committee on Fraud. He is a member of MENSA and the International Association of Forensic Linguists.

Comer has written nine4 books on fraud, corruption and forensic linguistics which have been translated into Spanish, Portuguese, German, Thai, Russian and Chinese.“Corporate Fraud III” has become a best seller. The book was extensively referenced by the Treadway Commission in its COSO standards.  His new book “Corruption and Bribery” was published in April 2013.

Mike Comer has been at the front line in preventing, detecting and investigating corruption for the past 40 years :
  • Advising on and investigating the anti-fraud and corruption work of the Esso-Shell-BP joint investments in the North Sea: making multi-million pound recoveries from overcharging by supposedly reputable contractors;
  • For nine years advising the Jamaican government, working inside its Revenue Protection Division. In this role he observed first-hand how and why organisations become  corrupt and how they can be transformed;
  • Advising and working inside revenue departments in four ASEAN countries and supporting SGS on its Customs and inspection services in Indonesia, Philippines, Malaysia, Taiwan and Hong Kong;
  • Advising Anti-Corruption Units in Indonesia, Brunei and Malaysia;
  • Directing scores of corruption investigations in the construction, banking, entertainment and pharmaceuticals sectors throughout the world and working as lead investigator for three major banks in the $2 billion Solo Industries corruption case in the UAE;
  • Advising leading companies in the oil and gas, extractive and financial services sectors on controls, audit and continuous monitoring programmes that surpass the requirements of the Bribery Act  (UKBA) and Foreign Corrupt Practices Act (FCPA);
  • For 18 months served  as a Monitor and expert witness—under the direction of Peter Taylor QC—for two public companies which were subject to regulatory action.
He has also been responsible for marketing his companies’ services world-wide, often in countries perceived to be corrupt. He has succeeded without ever paying or receiving a bribe, by being able to recognise vulnerable contexts and using “verbal judo” techniques which he now teaches to in company teams.

Tim Leech: Senior Associate

Tim J Leech is the founder and Managing Director of Risk Oversight Inc, based Calgary and Toronto, Canada and a Senior Associate with Cobasco Group Limited. He is recognised globally as a leading expert in the areas of governance, risk and compliance, enterprise risk management, risk and control self-assessment, fraud prevention and investigation, anti-money laundering, Sarbanes Oxley and officer and director due diligence.

Prior to founding Risk Oversight Inc, Tim served as a Director of GRC services with Navigant Consulting after a three-year contract as Chief Methodology Officer with Paisley/Thomson/Reuters, a leading provider of enterprise GRC software solutions.

From 1991 to 2004, Tim was founder and CEO of CARD® decisions, a global pioneer in enterprise risk and assurance training and software. His earlier positions include Managing Director(alongside Mike Comer) of Network Security Management (Canada) Ltd, a subsidiary of Hambros Bank and Director Control and Risk Management Solutions with C&L.

In 1997 Tim was elected fellow of the Ontario CA Institute in recognition of distinguished service to the profession and in 2006 as a certified IT specialist. He was retained by the Institute of Management Accountants from 2004- 2008 is a Director of its finance GRC research practice in Montvale, New Jersey. While in that role he authored a range of research studies and technical papers to the SEC, PCAOB and US Congress on areas for improvement in Sarbanes Oxley and regulation. He has provided training on assurance transformation and internal audit re-engineering for tens of thousands of public and private sector professional accountants and auditors in Canada, the USA, the EU, Australia, South America, Africa and the Middle and Far East.

3 With Tim Stephens who died in April 2012. Cobasco is a play on and abbreviation of “Comer – Older But wiser and Stephens Company”
4 His “friends” say it’s the same book nine times

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