"The cost of not being FCPA compliant, however, can be far higher." Assistant Attorney General , Lanny A. Breuer
Specific Anti-Bribery & Corruption or "ABC" analytics
Executives need to be acutely aware of the liability they face personally for the actions of their employees and business partners. They also need to have a robust plan to detect and prevent any improper activity.
Corruption and bribery risk is unlike other fraud risk, as it will always involve collusion of someone inside the company brokering a bribe or payoff to someone outside the company.
It is difficult to uncover bribery and collusion
As collusion is often the most difficult fraud to uncover, companies need to be innovative in developing systems and methods to manage this risk.
Internal Audit is well positioned to develop and embed a risk-based approach to anti-bribery and anti-corruption into its broader risk strategy. But to effectively detect and manage irregular activity, Internal Audit needs to move beyond traditional "rules-based queries and analytics" that are designed for process- and controls-related testing.
ABC analytics use targeted data analytics, text mining, visualization tools and statistics to identify and monitor data trends and potential irregularities in high-risk areas that could suggest the presence of bribery and corruption within the organization.
They're easy to use, make better use of auditors' time in the field, quickly identify anomalies or areas to investigate and provide a systematic methodology.
They will reduce risk and demonstrate to regulators the company's dedication and diligence in implementing and monitoring anti-bribery and anti-corruption policies.
"We recognize the issues of costs to companies to implement robust compliance programs, to hire outside counsel to conduct in-depth internal investigations, and to forego certain business opportunities that are tainted with corruption. Those costs are significant and we are very aware of that fact. The cost of not being FCPA compliant, however, can be far higher."
– Assistant Attorney General
Lanny A. Breuer