Consider how a fraud audit using data analytics can help to detect or prevent bribery and corruption where the primary sales force used by a company are China based employees defrauding their company by using false expense reports to create a pot of money to use as a slush fund to pay bribes. Here you can think back to the Eli Lilly FCPA enforcement action up to the GSK problems as examples of where employees used their expense accounts not for personal use but for greater corporate malfeasance.

This double dipping technique led to two anti-bribery compliance enforcement actions. One in the U.S. involving Eli Lily and a second in China involving the U.K. pharmaceutical entity GSK. The risk is real and by using ongoing data monitoring you might not only get ahead of the legal violation, but you would have a much more efficient business process going forward.

Three key takeaways:

  1. The typical fraud audit will get down into the weeds with data analytics.
  2. Split dollar expenses are key metric.
  3. Double-dipping can lead to larger problems.