Sharon J Zealey Introduction to analytics review for IFBEC AP Transactions Pcard payments TampL expenses Petty Cash transactions Third party payments Charity Political contributions ID: 647379
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Slide1
October 26, 2017
Using Data Analytics to Enhance Your Anti-Corruption
Sharon J. ZealeySlide2
Introduction to analytics review for IFBEC
AP Transactions
P-card payments
T&L expenses Petty Cash transactions
Third party payments
Charity
Political contributions
Gifts
Entertainment Sponsorships Education support Facilitating paymentsGovernment contracts Segregation of Duties Sales and Marketing Education support Export/Import
Non-compliance to Regulations & Company PoliciesFraudulent/Improper/duplicate payments Segregation of Duty conflictsIneffective review and approval mechanism
Development of Policies and ProceduresTraining and AwarenessTransaction testing and review
Various laws worldwide prohibit corrupt payments to foreign officials for the purpose of “obtaining or retaining business.” Corporations are required to make and keep books and records that accurately and fairly reflect transactions. Non-compliance could lead to civil and criminal penalties, including imprisonment.
Fraud and regulatory analytics
approach
should cover
review of all payment
methods, potential passive
bribery and both government and private party contracts /transactions . Slide3
Use a methodology that is in line with
regulatory expectations as outlined by SEC & DOJ to implement a continuous monitoring framework for all payables and expenses with focus on expenses incurred on government and other high risk third
parties. Methodology
Highlights
Data Analytics Methodology
Review Big Data from disparate sources
Data can be ingested from disparate ERP and T&E systems
like
SAP, Oracle, Concur etc.
Identification and flagging of
repeat red flags, ensuring false positives
are saved in system and
do not reappear in subsequent red flags
Machine Learning & Domain
Expertise
Digitally
Enabled- (
smart workflows and advance visualization)
Wider coverage with linkage to external Databases
like OFAC sanctions, SDN sanctions,
World
Bank sanctions across 50+ countries.
Smart Workflows and Integrated Dashboards with drill-down
capability
Inbuilt workflow for sample review and substantive testing – audit trail
and comments can be stored in the WF
Based on
common trends, market insights
, etc. the
rules are continuously modified
Key learning
from analytics is used to
update the compliance policy
and
program
of the companySlide4
Anti
Bribery Analytics (AP and T&E) by Genpact
No
Test performed
Analytic
objective
T&E
AP
1
Key
word search test
Identify transactions that could indicate Policy/FCPA/ regulatory violations including gifts, political contributions, entertainment and charitable contributions
2
Suspicious MCC
Identifies
potentially-improper
charges submitted
by
flagging merchants having a suspicious Merchant Classification Code (MCC)
3
Prohibited vendors
Identify transactions with sanctioned/ prohibited vendors using external data sources
4
Unusual Expenses
Identifies
suspicious transactions where the report contains
potential
conflicting claims like
T
ransactions on weekends and repetitive
expenses with same vendor
5
Policy Compliance
Identifies
non
reimbursable
expenses / prohibited expenses
in accordance with
applicable
Company
policies.
6
Top Transactions
Identifies
both the largest spenders and largest transactions in each expense category
like meals,
events, etc
7
Suspicious
Mileage
Conflicting
travel expense claims submitted for same day such as both air travel & car; fuel, taxi & car rental etc.
8
Duplicate Payments
Identify employees charging on T&E-Card the same expense twice/ routing same expense through
cash & card
9
Threshold Limit
Identifies
employees who consistently claim amounts just below approval thresholds, or attempt to use a large number of small currency charges to hide spending
activity
10
Even Dollar Transactions
Identifies
all individual charges evenly divisible by a specified parameter value (e.g. 100
).
Even-dollar charges usually represent the purchase of gift cards, vendor advances, or other similar purchases.
11
AP Expenses
Identifies T&E
c
ard
expenses that should have processed through
AP
and AP expenses charged to T&E cards
12
Cash
Transactions
Identifies
T&L where the employee did not use the Corporate Business
Card.
14
Split
Transactions
Identifies employees charging amounts to the card more than once to circumvent the spending limits or hide large expenses. Splitting transactions could occur within the same employee card, with more than one card
15
Transactions with High Risk Countries
Identify High risk payments to Government entities / corruption prone countries per CPI Index
16
Flip-Flop Bank Accounts / Alternate Payee Name
Identify vendors with more than one change to bank account number / alternate payee name within a specified time period (if details available)
17
Payments to individuals
Identify payments
made directly to
individuals of a company instead of the company name