Evaluating Compliance Systems and Procedures

Periodically testing the efficacy of compliance systems is a necessary step in the risk mitigation process.  Early detection of wrongdoing is critical to reducing the myriad of potential costs (i.e., fines, disgorgement, investigations, litigation) associated with non-compliance.  It is no longer a question of whether your compliance function should be tested, and weaknesses addressed, but how often this analysis is performed. We have substantial experience in this area.

• Performed a proactive fraud review for global provider of specialty engineering services. Lead investigation into allegations of self-dealing, bribery, and kickbacks by the in-country manager for operations in parts of Africa. Analyzed vendor transactions to determine whether this individual paid for products and services that were never received, or if he paid in excess of fair value for products and services received.
• Conducted compliance investigations for a global drilling company. Managed compliance investigation of a current agent and potential JV partner concerning potential conflicts of interest, false documentation, and bribery (both commercial and governmental) in Africa. Analyzed various accounting data, supporting documentation, and conducted interviews of employees. Identified gaps in both the policies and control environment and proposed measures to mitigate weaknesses. Prepared a report of our findings for the in-house legal team.
• Performed anti-corruption risk assessment for a global water company. Analyzed their sales, operating, and country specific risks associated with providing clean water solutions to government entities outside the United States. Presented a comprehensive list of measures to remediate their current anti-corruption policies and controls considering identified risks in their sales and distribution network and throughout their supply chain.