Dec. 2, 2020

Artificial Intelligence for Anti-Corruption Compliance: Building a Model

With AI one of the biggest buzzwords in the compliance industry, many companies may be wondering if an artificial intelligence tool might be right for their compliance programs. In the first article in this series, we attempted to demystify what AI is – and is not – and its relationship to other compliance tools such as machine learning and data analytics. In this second article, we look at the “how” of building an AI tool, including assembling a team to work on the project, defining the problem, building the model and improving it over time. See “Real Risks, Artificial Intelligence: The Next Wave of Anti-Corruption Compliance?” (Feb. 21, 2018).

Conflicts of Interest and Improper Commissions Lead to Airline Services’ SFO DPA

Airlines Services Limited’s DPA with the SFO has been judicially approved, and the now-defunct company will pay approximately £2.98 million ($3.99 million) to resolve the commercial bribery case, which highlights the risk of commission structures and the failure to follow through on anti-bribery programs. We analyze the case, the ninth DPA for the SFO since the resolution tool was introduced. See “What Does a ‘Bigger and Stronger’ SFO Mean for Companies?” (Nov. 28, 2018).

How Visual Analytics Can Fuel a Compliance Program

Even as companies focus more on gathering data, it is not always clear what type of analysis will provide a compliance department with the most value. In a guest article, Andy Miller, chief analytics officer at Lextegrity, argues that a focus on providing data in a user-friendly, eye-catching way is the most efficient route to gaining insights from compliance data. He explains how data visualizations can add value to a compliance program and gives three examples of the contexts in which a compliance program could effectively make use of visual analytics. For more from Lextegrity, see “Continuous Spend Monitoring for End-to-End Third-Party Risk Management” (Dec. 11, 2019).

Cross-Border Internal Investigations in Spain: The Legal and Practical Landscape

If not carefully considered, cross-border investigations involving Latin American nations as well as Spain, which have cultural, language and regional affinities, can easily go astray. In a guest article series, Daniel R. Alonso, a partner at Buckley, teams up with local attorneys in Spain, Argentina, Brazil, Colombia and Mexico to explore the framework for government and internal investigations. In this first article, Alonso pairs with Garrigues attorneys Helena Prieto González, José Fernández Iglesias and Alejandro Ayala González to lay out the criminal process, criminal and civil liability of legal entities and persons, and the role of corporate compliance programs in Spain. The second article focusing on Spain will address conducting internal investigations, including issues related to attorney-client privilege, document retention, conducting interviews and self-disclosure. See “Regional Risk Spotlight: Corruption Perceptions and Compliance Expectations in Spain” (May 24, 2017).

How Lockheed Uses Big Data to Evaluate Risk at Small Worksites

In a large organization, small worksites can present unique ethics and compliance challenges, especially when they lack close connections to the organization’s primary locations. Defense giant Lockheed Martin has developed an ethics site risk assessment database to tackle these challenges and inform its ethics engagement activities. At a recent SCCE program, Lockheed’s ethics director and senior manager discussed how the database was developed and functions, and how Lockheed discovered and responded to serious unreported ethics issues at one of its small worksites. See “Using Data Analytics to Boost Compliance Program Effectiveness” (Jun. 27, 2018).

Control Risks Welcomes Evan Lieberman as Principal in Compliance, Forensics and Intelligence Practice

Lieberman has more than 30 years of experience as a litigator, consultant and investigator and he joins from WIT Legal, a division of DOAR, where he was a managing director.