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Oversight FCPA Solutions: NOT a check-the-box exercise, Pt 3- Context

on August 18, 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 blog, Fox warns against taking a check-the-box approach when evaluating for FCPA risk.

In earlier posts, I discussed 2 ways that Oversight’s FCPA solutions are anything but simple; our solution can monitor for country risk, and translate national languages so you can be fully prepared for any type of fraudulent activity.

There is a third way that Oversight's solution is markedly different from the simple check-the-box approach, and that is in our ability to present an overview of the potential violation, all of the details of the specific transaction, and the full context in which it took place. I refer to this as Reviewing in Context.

When I demonstrate our solutions to potential customers, many expect us to produce a “report”. Oversight doesn’t just display the results of our analytics as static reports. Instead, our Oversight Workbench gives you a 360 degree view around the transaction that was flagged.

Let’s say that Oversight created an outlier exception for an entertainment expense that took place in China, and the expense was flagged for being exceptionally high for the geographic area. These are some specific ways that the Oversight Workbench gives you additional context while reviewing this exception:

Related Entities

When reviewing this exception, the Oversight Workbench makes available any and all data related to this particular transaction. For example:

  • Who was listed as attendees for this expense?
  • What country is the employee based in?
  • What are the other items reported on this same expense report?

But also at your fingertips is the full history of all activity for this employee or this merchant, not just the details related to this particular exception. For example:

  • What is the history of card charges for this employee?
  • Are any other employees doing business with this same merchant?
  • Did this employee enter multiple expense reports in this same time period?

Related Exceptions

While reviewing this Outlier exception, you can review and research any other exceptions that were generated for this expense, card transaction, employee, merchant, expense attendees, etc.

For example, we might find by looking at related exceptions…

  • This same transaction has an attendee that was flagged by Oversight as a Politically Exposed Person…
  • This employee has an unusual amount of cash expenses…
  • This employee also had hits on keywords that pose a high level of FCPA risk...

These contextual features power your review by building a richer, clearer picture than you could ever see by looking at the transaction in isolation. Oversight makes all of the information available that you need to follow up appropriately.

Julia Versaci

Julia Versaci is Director of Solutions Development at Oversight Systems.