For the Defense - Vol. 3, Issue 2 - 2018 - 41

not only identifies red flags, but also reveals
causes and enhances a company's ability to take
the necessary steps to remediate and prevent a
recurrence.
The DoJ and SEC continually cite certain
areas that are ripe for bribery and corruption,
and in recent years there have been several
enforcement actions involving corrupt
payments that were miscategorized as travel
or entertainment. The Guide itself provides
examples of improper travel and entertainment
expenses.15 Travel and entertainment are prime
for data analytics and visualization tools as
they allow the company to interrogate expense
data using a variety of lenses to drive business
insight, find potential high-risk expenditures and
highlight opportunities for cost savings. Rather
than selecting a random sample with the sole
purpose of finding exceptions, data analytics
go further by providing visibility into repeat
offenders. This strengthens the organization's
ability to mitigate bribery and corruption risk

A white-collar or government
enforcement invesঞgaঞon
can be the most complex legal
challenge a company or
individual faces.
Using skills honed through years of experience,
Stradley Ronon's lawyers guide clients through
some of their most delicate and potenঞally
damaging situaঞons. Clients regularly call
on us to conduct comprehensive internal
invesঞgaঞons, create and implement effecঞve
corporate compliance programs, and defend
against allegaঞons of white-collar crime.

and to quantify potential cost savings through
changes to travel & entertainment policies.
Trends can be discovered through analytics and
visualization that may reveal increased levels of
non-compliance among certain employees or
external parties, and compliance personnel will
have the ability to drill down into transactions
for further detail. Importantly, compliance
personnel also have the ability to monitor
and refresh their travel and entertainment
expenses dashboard, meaning transactions
can be reviewed in real-time or via automated
notifications as red flags occur. This form of realtime, continuous monitoring removes the time
gap that traditionally exists in periodic reviews,
and allows the company to respond quickly to
potential bribery and corruption.
Since the 1970s, compliance programs have
continued to evolve in response to global trends
and regulatory expectations. As spending on
compliance continues to rise and bribery and
corruption remains at the forefront of the news,
companies must explore ways to proactively
address this omnipresent risk. Pouring
significant investment into outdated programs
has proven ineffective, as many compliance
programs appear to be "going through the
motions" rather than embracing a culture of
compliance. Data analytics and visualization
tools provide organizations the ability to
generate instantaneous results and make realtime decisions. Compliance programs must be
tailored to the organization, and embracing data
analytics provides the framework for creating a
program that is built to accommodate change
and evolve with the company.
PANTONE

2955C

7406C

CMYK

90/78/39/30

22/58/92

Michael J. Engle

www.stradley.com
www.stradley.com
Pennsylvania
Pennsylvania || Washington,
Washington, D.C.
D.C. || New
New York
York || New
New Jersey
Jersey || Illinois
Illinois || Delaware
Delaware

234/194/56

1. The Foreign Corrupt Practices Act of 1977 (FCPA), Pub.
L. 95-213, 91 Stat. 1494 (1977), 15 U.S.C. §§78dd-1, et
seq.
2. Criminal Division of the U.S. Department of Justice
and the Enforcement Division of the U.S. Securities
and Exchange Commission (November 14, 2012). "A
Resource Guide to the U.S. Foreign Corrupt Practices
Act" (PDF). Available at https://www.justice.gov/sites/
default/files/criminal-fraud/legacy/2015/01/16/guide.pdf
3. Deputy Attorney General Rosenstein Delivers Remarks
at the 34th International Conference on the Foreign
HEXIDECIMAL

#153A5B

Chair
Chair ,, White-Collar
White-Collar Defense,
Defense, Internal
Internal Investigations
Investigations &
& Corporate
Corporate Compliance
Compliance
215.564
215.564 .8737
.8737 || mengle@stradley.com
mengle@stradley.com

9/22/91/0

RGB

NOTES:

Vol. 3, Issue 2

For The Defense

#EAC137

https://www.justice.gov/sites/default/files/criminal-fraud/legacy/2015/01/16/guide.pdf https://www.justice.gov/sites/default/files/criminal-fraud/legacy/2015/01/16/guide.pdf http://www.stradley.com

Table of Contents for the Digital Edition of For the Defense - Vol. 3, Issue 2 - 2018