Using Data Analytics to Meet the Government’s Anti-Corruption Compliance Expectations

The SEC and DOJ’s FCPA Resource Guide outlines ten “Hallmarks of an Effective Compliance Program” that provide prescriptive guidance about what the DOJ and the SEC consider to be critical components of an effective compliance program. But, what are compliance officers and chief audit executives to do in response to this regulatory “perfect world” of compliance? With limited resources and competing priorities in the real world, where should compliance officers and chief audit executives focus their efforts to meet this guidance? The answer is data analytics, Grant Thornton’s Bill Olsen, Dan Reynolds and Alex Koltsov say in a guest article. They argue that when used properly, data analytics is proactive, risk-based, scalable, repeatable and defensible against after-the-fact scrutiny. The article focuses on how two regulatory program “hallmarks,” ABAC risk assessment and continuous improvement and monitoring, can be addressed by data analytics. See also “Ernst & Young Experts Reveal How Forensic Data Analytics Can Transform Anti-Corruption Compliance” (Apr. 30, 2014).

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