Owner
Alfred Spencer III
Founder, AS3 Compliance Consulting · 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 self-assessment
Compliance leaders are often asked a simple question by their board or their lawyers: “How strong is our program?” Alfred built the AS3 Anti-Corruption Self-Assessment to make the answer clear, and easy to show. It is based on the U.S. Department of Justice’s guidance on evaluating compliance programs (September 2024), with ISO 37001 mapping.
Focus areas
- FCPA and anti-corruption programs
- Third-party due diligence and oversight
- Reporting to senior management and the board