At Oversight, we’ve been investing a lot of energy into developing our platform for Insights On Demand™ for FCPA. Recently we read Joseph Spinelli’s article on The FCPA Blog, “Expect DOJ Investigations to Become Very Personal” wherein he recommends the following proactive steps for companies looking to protect themselves from FCPA vulnerabilities:
- Design and implementation of an effective compliance program, coupled with employee training for all senior corporate executives - including members of the board
- Management support of those compliance efforts including adequate resources and active oversight by senior management and board members
- Immediate management response to potential corporate fraud issues brought to their attention
- Illustrating evidence that senior management and the board are committed to zero tolerance for corruption and are dedicated to operating their corporation in an ethical manner.
Our Insights On Demand for FCPA solution speaks to a lot of the bullet points listed above. What makes our software perfect for ensuring FCPA compliance?
In addition to just looking at one expense report or one purchase transaction at a time for high risk activity, our analytics look for behaviors or patterns of FCPA risk across all expense reports and card transactions in T&E, and across all invoices and payments in AP. We also benchmark all transactions for additional outlier comparisons.
Our FCPA risk analytics look across various dimensions such as employees, attendees, vendors, and countries over an extended time horizon. This enables us to identify employees exhibiting patterns of potentially improper behavior or collusion that are difficult to detect in traditional FCPA monitoring and audit approaches. From the analysis, we precisely identify FCPA risk in the form of cases that require investigation and resolution.
An FCPA solution such as Oversight’s is certainly an important part of demonstrating an effective compliance program because it addresses several key DOJ guidelines for monitoring transactions for improper behavior, assisting in performing compliance audits, and being able to demonstrate communication with employees around policy reminders and warnings.
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