FCPA – we’re talking about it all month long. If you keep up with FCPA news (like we do) you’ll know that creating a culture of compliance is more important to the Department of Justice than ever before. In this great article, writer Worth MacMurray states:
“The "culture of compliance" concept thus appears to be taking on increased importance with DOJ. Why is this so? One interpretation is that the Department has seen too many examples over the years of companies asserting that they had an effective compliance program, but the subsequent review shows a “check the box,” rather than substantive program foundation. “
What is the culture of compliance? It’s not just about how are you doing business but that compliance is embedded into the way all of your employees act and transact business on a day-to-day basis.
So, how do we embed substantive compliance into our day-to-day business activities? One answer is leveraging transaction monitoring to drive a culture of compliance in organizations.
The good news is most of your employees are likely operating with a high degree of integrity. For most organizations the issue is finding the relatively small handful of people who are--at best--pushing the envelope, or at worst blatantly transgressing your compliance policies.
Instead of pushing standards for ethical behavior over and over again to all employees, it can be more effective to influence the behavior of the small number of people who are engaging in risky activities.
What we're seeing more and more is organizations using automated transaction monitoring to identify that small number. Artificial intelligence based, analytical software evaluates all transactions to find the relatively few that represent the greatest risk of Foreign Corrupt Practices Act violations.
These systems have an integrated case management capability, because let’s face it-you're going to find some things that at least merit a closer look.
You’ll want to be able to efficiently follow up with employees, track their responses, and understand what their case history is so you can find the repeat offenders and (if the time comes) generate documentation.
So, to create a substantive and cost effective improvement to your compliance program, look for an integrated case management tool tied in with sophisticated analytics. It creates an effective one-two punch.
P.S. Read about how our FCPA solutions are more than a check the box exercise.
