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“Good” is Often Better Than Doing Nothing At All When It Comes to FCPA

on February 12, 2015

I just read a great article from FCPAblog.com about how transaction monitoring (what we here at Oversight specialize in) is the new “must have” item for anti-corruption practices in 2015. This was a great blog to read, and even better news to hear, because at Oversight we agree that monitoring transactions is one of the easiest ways to strengthen your audit and anti-corruption programs.

We are able to offer this as turnkey solution by pairing analysis with a case management tool and powerful dashboard reporting system. It’s called Insights On Demand™ because users can select when they’d like to analyze transactions: either daily, monthly, or quarterly. While we’ve built these solutions to be cheaper, and easier to use than traditional software systems, I was shocked to read on the blog that the author thinks transaction monitoring can actually increase risk.

“Transaction monitoring increases legal risk when generic monitoring programs produce thousands of false positives -- typically, far too many to investigate,” authors Jonny Frank and Rex Homme write. “These unpursued transactions can become a government treasure trove for subsequent scrutiny.”

Our software combats this because, yes IOD makes it easy to monitor 100% of transactions, but after ten years spent analyzing trillions in transaction, we’ve been able to hone our analytics to minimize false positives and generate results that alert you to legitimate instances of fraud, waste, and misuse.

The key to having a defensible transaction monitoring program is to automate the process so that it generates the “documentation” necessary to prove what you did. Within Oversight’s case management tool we have an integrated email system, and tamper-proof case log so that findings can’t be disputed. Customers report they spend less time and effort monitoring 100% of the transactions with our system than when they only audited a sample of the transactions.

The compliance process doesn’t have to be perfect, but it can’t be arbitrary either. Many of the cumbersome compliance methods listed in the article prevent companies from implementing anything at all, as opposed to a solution that audits transactions automatically. It is definitely better than the “do nothing” approach, and best of all it is defensible. Our workflow addresses that for you.

To see our software in action, take a free test drive.

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