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Oversight FCPA Solutions: NOT a check-the-box exercise, Pt 1- Risk

on July 09, 2015

Julia Versaci

As one of the solution designers for Oversight’s FCPA compliance modules, I keep an eye on the news regarding FCPA to make sure that our solution remains on target. I recently came across a great multi-part series of articles entitled “Why Should Americans Care About the FIFA Indictments?” by Thomas Fox.

In this installment, Fox points out that:

“… now would be a very propitious time to review your internal controls; for even if you had a robust paper system of internal controls like BHP Billiton did, if it is simply a check-the-box exercise or even worse you do not follow the internal compliance controls you have in place, you should begin remediation now.”

This got me thinking of all of the ways that Oversight Systems FCPA solutions are not a simple check-the-box exercise, but so much more.

The first topic is Country Risk.

Let's say that your company has millions of transactions a year, either through accounts payable or on corporate issued travel cards, or both. Your job is to audit these transactions for FCPA risk.

So where do you start?

A simple "check-the-box" approach might be to run a query to produce a report of transactions that took place in foreign countries, and look more closely into a random sample of those foreign transactions.

In contrast, Oversight's sophisticated technology automatically scans transactions for this risk, and guides you to the areas that pose the most danger of FCPA exposure to your company. One way that we do this is by using intelligent risk-aware analytics that automatically evaluate Country Risk.

Most of us would look more closely at a transaction that took place in Iraq than one that took place in Denmark. However, is a transaction that takes place in Barbados more or less risky than one that takes place in Jamaica? Which countries are riskier than others? Don’t worry, we handle that for you.

Transactions can also have a hidden risk of corruption that isn’t immediately visible by analyzing the country where the transaction took place. One example of this is that an employee who lives in a country where corruption is a way of life may carry that “culture of corruption” with them, even when doing business in a country where corruption is less prevalent.

Oversight’s multi-dimensional approach to country risk adds layers of depth around a potentially risky transaction to help you determine the true FCPA risk of a situation, instead of simply viewing the expense from a single data point about the country recorded on the transaction.


Julia Versaci

Julia Versaci is Director of Solutions Development at Oversight Systems.