For the Defense - Vol. 3, Issue 2 - 2018 - 40

However, bribery and corruption detection
methods are not keeping pace, as only 37% of
U.S. respondents have performed an ABAC risk
assessment in the last 24 months.14 Traditionally,
risk assessments are often conducted based on
professional judgement and limited sampling
despite the complexity of a global enterprise.
Data analytics enables companies to conduct a
more holistic ABAC risk assessment which then
allows for a targeted response and allocation of
resources. By aggregating data from disparate
sources, organizations are provided insights into
previously unknown relationships, trends, and
outliers. Additionally, once aggregated, leaders
can analyze the population of transactions that
may drive non-compliance, rather than pull
separate samples from disconnected data sources.
Rules can be integrated into the compliance
program to actively monitor policy exceptions
and identify red flags, and risk-based sampling
can be conducted on the universe of data based
on those rules or criteria that are relevant to

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the company's particular operations. Take for
example, a global engineering, procurement,
and construction company with operations in
Africa. As it seeks to assess its potential bribery
and corruption risk exposure at the company's
operations across sub-Saharan Africa, it's looking
at policies, controls and actual transactions.
The company can extract large amounts of
transactional data such as payments data
relating to numerous country markets and utilize
the power of data analytics to identify patterns
of spend and potential breaches of company
policy and relevant regulations. Starting
with actual patterns of transactions helps the
company identify more about business activities
and local practices from the data upwards.
This approach enriches their assessment and
allows for further enhancements to policies and
controls. Additionally, the company can utilize
the data to highlight areas of expenditure with
heightened risks of bribery and corruption.
Rather than incurring hundreds of man hours,
this approach would allow the company to not
only identify potentially problematic payments
involving local "chiefs," but also allows it to
remediate more efficiently and enhance its
policies, procedures, and controls around high
risk transaction types.
As the volume of meaningful data continues
to grow and the quantity and nature of valuable
data sources expands, it is increasingly important
to visualize links that indicate a potential threat
or risk to the organization. Companies can
implement data visualization tools that connect
directly to aggregate data sets and refreshes on
demand. This allows insight, trends or red flags
to be identified on an ongoing basis rather than
at a static point in time, and decision makers can
display and analyze the results in an effective
and concise manner - ready for the Board or
key management. Ultimately, data analytics
can convert a one-time risk assessment into an
active platform that can continuously improve
and integrate new business developments. An
additional Hallmark of an effective program,
continuous improvement is made possible
through this commitment to data analytics,
which can support that the compliance program
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Table of Contents for the Digital Edition of For the Defense - Vol. 3, Issue 2 - 2018
