FCPA Compliance Audit‍

An AmLaw 10 law firm, representing a global entertainment company that received a Second Request from the U.S. Department of Justice (DOJ) in connection with a proposed $60 billion acquisition, had been given 60 days to analyze, review and produce responsive material from a 30 Terabyte document collection.

Challenges

Solution

Using a description of potential fraudulent activity provided by one of the internal auditors, the client was able to quickly identify FCPA violations by leveraging Brainspace’s Transparent Concept. Concept Search provides a simple and powerful method for exploring topics of interest across large volumes of unstructured data. As suspicious emails were identified, auditors built additional Concept Searches using key blocks of text from each communication. Additionally, the auditors took advantage of Brainspace’s Communication Analysis visualization to identify additional persons of interest. The Comm Analysis is an interactive network communication graph that allows you to quickly understand who was communicating with whom as well as their level of participation in the conversation. The auditors agreed that the Brainspace interface was highly intuitive allowing users to gain valuable insight into their data within the first few minutes.

Results

By leveraging Brainspace to develop a consistent and efficient process to proactively detect fraudulent activity, the client was able to dramatically reduce regulatory risk and and avoid costly government fines. The client now has a proven self-policing audit process that ensures they remain in compliance with the Foreign Corrupt Practices Act.

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