Risk Management Magazine recently published an article by ACL’s Chris Stewart-Smith “Avoiding FCPA Violations with Data Analysis.” Chris discusses how to address FCPA issues faced during mergers & acquisitions, and explains both the how and why data analysis should be part of your FCPA compliance program.
Here is an excerpt:
Analytics can also uncover suspicious situations that may warrant further investigation, including high cash transaction volumes, payments sent outside the country of operation, multiple gifts to a single individual, entertainment of government customers, bonuses of unusual quantity or timing or charitable contributions to organizations affiliated with the government.
Instilling a culture of continuous monitoring backed by effective controls can strengthen compliance efforts. Companies that are transparent with their monitoring practices give employees the impression that inappropriate actions might be questioned. This, in turn, can lead to a decline in fraudulent activities.
Data analysis technology can be particularly effective in enabling internal audit, finance, IT and business teams to identify and stay on top of internal control issues. This leads to the creation of detailed, objective, data-based evidence that fully conveys the nature of issues and the progress of resolution actions to senior management.
One example of where data analytics can be helpful in avoiding FCPA issues is in mergers and acquisitions. Mergers can sometimes introduce the possibility of acquiring another company’s FCPA violations.
Read the entire article Avoiding FCPA Violations with Data Analysis
About Christopher Stewart-Smith
A Senior Consultant with ACL Services, Chris works with clients across North America to help them realize the benefits of data analytics and audit and compliance management technology and bridge the knowledge gap between the IT department and business leaders. With over 15 years’ experience in software consulting and training across a broad range of industries, Chris is considered a data analytics expert. He is a frequent speaker and educator on the topics of Continuous Auditing & Monitoring. Chris has an Honors degree from The University of Birmingham and the Université de Nantes


