Sonny Carpenter, in his Criminal Justice article, “Avoid an Investigation: Automate FCPA Compliance”, makes one of the more succinct and clearly reasoned cases I have seen for companies to automate their approaches to ensuring FCPA compliance. Mr. Carpenter makes the case that technology can assist companies to ensure FCPA compliance by:
- Continuously monitor key controls
- Monitor activity in traditionally risky areas such as T&E, political contributions, consultant fees, and petty cash
- Identify high-risk transactions like duplicate payments, round-dollar payments, cash distributions, and multiple payments to a single entity over a short period of time
Mr. Carpenter makes the case that applying technology to these high risk areas is a useful way for senior executives to guard against the risk of designating a “control person” who assumes liability for the acts of an employee who may be doing something 6,000 miles away from headquarters that is in violation of both company policy and US laws. Oversight has long advocated for the use of technology as a way to automate compliance, and it is nice to see others in the industry catching on to the trend.
Many of our customers who leverage Insights On Demand for FCPA to monitor high risk transactions in T&E and accounts payable tell us that automated monitoring of 100% of these expense transactions helps them to focus on the highest risk transactions, identify the validity of potential risks, and take actions to address the causes. Because these solutions are available as web-based insights into their highest risk transactions, the cost of ongoing use is low, there are no set up fees, and the implementation period is less than four weeks and often as little as a couple of weeks.
With the ease of implementation and low cost, leveraging technology works well in the risk-reward equation for executives and compliance leaders.
