Tag: Integrity Audit

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31 Days to More Effective Compliance Programs

The Fraud Audit


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.
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31 Days to More Effective Compliance Programs

The Integrity Audit


Yet another way to consider using audit for continuous improvement is through the Integrity Audit. Mary Jo White in an article entitled “What I’ve Learned About White Collar Crime” provided insight into not only white-collar criminals but the integrity of companies. Her framework lays out a way for you to think through an underutilized tool for continuous improvement, the integrity audit.
When Mary Jo White or Jonathan Marks write, you need to read, digest what they have to say and implement their suggestions. The ideas that they forward are not new, revolutionary or in the least bit controversial. Yet integrity is not often considered by compliance professionals. With the Business Roundtable’s Statement of Corporate Purpose integrity has been driven to the forefront in the rasion d’etre of a corporation. Failing to have integrity at the top or down through your organization can lead to significant corporate calamity.
Three key takeaways:

  1. The Integrity Audit is an underutilized tool.
  2. Ego and arrogance at the CEO level can lead to catastrophic corporate failures.
  3. A robust report culture can demonstrate and facilitate corporate integrity.