International Mining Compliance Assessment

Challenge

A mining and construction company growing rapidly through international acquisitions found itself at risk of violating the Foreign Corrupt Practices Act (FCPA), UK Bribery Act, and other multijurisdictional anti-corruption regulations. Under a mandate to complete a compliance risk assessment of vendors within a tight deadline, the firm engaged FRA to assess hundreds of thousands of vendors spanning 63 countries and speaking 36 languages.

Action

Because of the highly diversified nature of operations and accounting systems across the business lines and the multiple reporting entities in the company’s Enterprise Resource Planning (ERP) system, FRA’s team first developed standard data structure requirements that could be applied to each of the ERP platforms. After identifying and consolidating more than 1.5 billion transactions and data points for analysis, the team then designed and executed a series of data analytics to identify vendors and transactions exhibiting red flags and a higher risk of corruption.

Results

FRA’s Mobile Solution allowed its client to simplify its original list of more than 900,000 vendors to a manageable 937 for review. An additional risk-scoring model (based on factors such as location, nature and value of services, and types of transactions) ultimately led to a number of in-country bribery and corruption investigations. Today, FRA’s client is in possession of an FRA designed and developed system for organizing third-party vendor data and is able to remotely monitor activities throughout the world to minimize exposure to legal and reputational fallout.