Legislation exists around the world prohibiting bribery payments to foreign officials and political figures, such as the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, implemented to fight bribery and corruption. The failure to prevent and detect issues of bribery can lead to a serious offense resulting in heavy penalties, reputational damages, and possible incarceration. When language and cultural traditions vary so widely, a comprehensive approach including policy development, risk exposure assessment, control implementation, and ongoing transactional data monitoring is required.
When it comes to managing and monitoring bribery malpractices, performing data analysis is the most powerful way to validate the completeness and accuracy of books and records.
An integrated risk assessment and data analytics workflow software solution allows you to evaluate and monitor strategic risks in real-time, while analyzing business data with no manual effort required. It’s now possible to link data analytic test results directly to enterprise risks in the same system and display easily-interpreted visualizations. Technology empowers senior leadership to quickly and consistently understand the potential impact of bribery and corruption risk across the organization.
When establishing an anti-bribery and anti-corruption (ABAC) program, a common mistake most organizations make is trying to ‘boil the ocean.’ An ABAC program that is deployed in bite-size manageable pieces ensures longevity and success.
Here are the top ten tests that organizations commonly deploy first.
Identify expense transactions where the vendor name (and attendee name in the case of meals) closely matches a name on the OFAC/GSA list or other supplied list of names (e.g., PEP list, prohibited vendors).
Identify payment transactions containing suspicious words in identified fields (e.g., description or comments fields) such as: gifts, services rendered, facilitation, cash.
Identify payment transactions to vendors or individuals in high risk countries.
Identify employees with more than a defined number of even-dollar cash expense transactions above a specific amount threshold in a specified time period.
Identify vendors with more than one change to bank account number within a specified time period.
Identify vendors with master data changes created and/or approved by an authorized employee.
Identify purchase orders where the total payment amount was greater than the total purchase order amount.
Identify Invoices where the invoice receipt amount is greater than the Goods Receipt amount.
Identification of vendors where alternate payee names have been flip-flopped within a specific time period.
Identify cumulative Payments for two or more transactions approved by same Employee to the same Vendor that exceeds or is within a Percentage Below Threshold of the Authority Limit.
These tests are the most valuable analytic tests proven effective as an early warning system against bribery and corruption that ACL has distilled from more than 25 years of experience working with more than 14,000 organizations worldwide. Use these tests as a guideline on where to get started on building your bribery and corruption detection program.
(Source: ACL Blog)