I recently came across a great multi-part series of articles entitled “Why Should Americans Care About the FIFA Indictments?” by Thomas Fox. In this installment, Fox warns against taking a check-the-box approach when evaluating for FCPA risk.
In earlier posts, I highlighted 3 ways that Oversight’s FCPA solution is not a simple “check-the-box” approach in that we evaluate for Country Risk, National Languages, and Context.
The fourth topic is Issue Tracking.
As I mentioned in my earlier post on Context, when I demonstrate our solutions to potential customers, many expect us to produce a “report”.
The Oversight Workbench experience couldn’t be more different from working with reports. The Workbench tracks every interaction and note taken during the research of the exception in a persistent log. This log, which is attached to the exception, can be used as supporting documentation for any disciplinary action that may result from your review.
What does all this mean to your process of reviewing transactions for FCPA risk?
- The Workbench presents the riskiest transactions at the top of the list so you can focus your review.
- From the workbench interface, you can send an email to the employee or buyer requesting more information about the transaction. The contents of the sent email are automatically logged with this exception, and the status is automatically changed to Email Sent.
- When the employee or buyer emails you back providing the requested information, the contents of the email that was received are automatically logged with this exception, and the status is automatically changed to Email Received.
- You can type additional notes, or upload a digital copy of the receipt with the exception.
Six months later, if your boss wants to see the details from the review of the particular transaction, they simply log in to Oversight, locate the exception, and review all of the notes, emails, and attachments tracked on the exception. No need to call you or visit your office.
These issue tracking capabilities are available in all of Oversight’s Insight families, not just FCPA. However, these tracking and logging capabilities are even more important when monitoring for regulatory compliance.
If it is your job to review your company's transactions for FCPA risk, which approach would you rather use? A report, or the Oversight Workbench?
