The FCPA Report

The definitive source of actionable intelligence covering the Foreign Corrupt Practices Act

Articles By Topic

By Topic: Transaction Monitoring

  • From Vol. 2 No.22 (Nov. 6, 2013)

    Five Lessons from 2013 FCPA Enforcement: Transaction Monitoring, International Cooperation, Documenting Hiring Decisions, Risk Assessments and Individual Prosecutions

    It has been a busy year for FCPA enforcement – the government has prosecuted individuals for violating the FCPA, used aggressive criminal investigation techniques to build cases and continued to increase its cooperation with foreign governments.  In a recent webinar hosted by The Network, Tom Fox shared his insight into recent FCPA trends and provided tips for FCPA compliance arising from those trends.  See also “Seven Key Trends That Are Changing the FCPA Enforcement and Compliance Landscape,” The FCPA Report, Vol. 2, No. 14 (Jul. 10. 2013).

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  • From Vol. 2 No.18 (Sep. 11, 2013)

    Fighting Corruption with Creative Data Mining: Five Forensic Accounting Techniques for Development Program Investigations

    The World Economic Forum estimates that the cost of corruption amounts to more than 5% of global GDP ($2.6 trillion), with more than $1 trillion paid in bribes each year.  Creative data mining is one of the most effective tools in identifying transactions connected to this illicit behavior.  It is commonplace in most every fraud and corruption investigation nowadays to pull raw data from ERP systems, identify relevant pools of data and design queries to find anomalies.  What happens, though, when an organization is faced with a situation where such raw data is unreliable, incomplete, or not available at all?  More often than not, the robust data sets that one would likely have access to in corporate investigations are not available in the case of development projects financed by institutions such as the United Nations and the World Bank.  Such projects are often plagued by inadequate accounting systems, archaic banking practices and a general lack of management and fiduciary controls.  In a guest article based on dozens of global corruption investigations, Jean-Michel Ferat, Managing Director at The Claro Group, describes the primary corruption risks inherent in development projects and – using slides taken directly from his investigative experience – details five workable methods for mitigating those risks.  See also “How Forensic Accountants Help Identify Corruption Risk and Delve into the Details of Books and Records,” The FCPA Report, Vol. 2, No. 12 (Jun. 12, 2013).

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  • From Vol. 2 No.4 (Feb. 20, 2013)

    How FCPA Transaction Monitoring Software Works

    To comply with the FCPA and other anti-corruption laws, companies operating multi-nationally must closely monitor the actions of their employees, agents and third-party partners for indications of potential bribery.  This is a costly proposition for any company, but especially for smaller companies that lack the human resources necessary to perform comprehensive anti-corruption reviews.  Enter technology.  Relatively recent software innovations allow companies to perform automated FCPA transaction monitoring, thereby enabling companies to track substantially the same number of transactions with fewer people and equal or greater effectiveness.  The FCPA Report recently had an extensive conversation regarding automated transaction monitoring with Patrick Taylor, CEO of Oversight Systems, a company that provides automated transaction monitoring solutions.  In our interview, Taylor explained the fundamentals of automated transaction monitoring; outlined what types of companies should consider transaction monitoring; and explained the benefits of implementing an automated system.

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