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Oversight FCPA Solutions: NOT a check-the-box exercise, Pt 2-Languages

on July 28, 2015

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 warns against taking a check-the-box approach when evaluating for FCPA risk.

In an earlier post on this topic, I discussed how Oversight’s handling of Country Risk is anything but simple. The second way that Oversight’s FCPA solution goes above and beyond your typical audit is via our National Language Features.

When evaluating international transactions for FCPA risk, often the descriptions of the transactions, the vendor or a merchant’s name may be in another language; possibly even in different character sets. Oversight has many features to help you review these transactions processed in unfamiliar National Languages with confidence.

For example, what if you wanted to look for particular words in your transactions that might indicate FCPA risk?

Fox mentions in his article referenced above, that "CBF had authorized Traffic to invoice Nike directly “for marketing fees earned upon successful negotiation and performance of the agreement”."

If the invoice was entered into their system with this same description, then it would be flagged on a text search for the word AGREEMENT.

However, what if the description that was entered on the invoice had looked like this?


.... or like this?

для маркетинговых сборов, полученных после успешного проведения переговоров и исполнения соглашение

Oversight handles situations like these by searching in multiple national languages, so that we will catch the word AGREEMENT whether it looks like “Agreement” or 协议 or соглашение.

This, and Oversight’s other National Language capabilities transform a text search from a simple report approach to a feature rich toolset that empowers you to uncover hidden bribery or corruption in your company’s financial transactions.


Julia Versaci

Julia Versaci is Director of Solutions Development at Oversight Systems.