After uncovering compliance violations within its operations in the Asia Pacific region, a global life sciences corporation decided to take a more targeted, proactive approach to finding problem areas and self-reporting them ahead of a regulatory inquiry. The organization engaged FTI Technology to support the internal compliance team with quarterly evaluations of randomly selected business segments and global communications monitoring.

Situation

Prior to engaging FTI Technology for compliance monitoring, the client had relied upon manual, highly laborious compliance monitoring initiatives that ultimately did not deliver the level of insight the organization needed to effectively monitor and enforce compliance worldwide and quickly review allegations from whistleblowers.

In one of the initial matters, the client needed an efficient, cost-effective way to evaluate a set of more than 40,000 documents for signs of potential compliance violations. Finding key facts within the documents and the broader storyline of activities among the business segment under review was a key imperative to help the compliance team identify any violations that warranted further investigation or self-reporting to relevant authorities.

Additionally, the compliance team needed a way to synthesize and report the findings back to executive leadership and the board, so they could understand the impact to the organization’s overall risk posture.

In another compliance-related review, FTI Technology was tasked with quickly elevating facts relating to internal whistleblower reports of closed and toxic work environments and nepotism within an isolated department of the organization. There were additional allegations that the group had accepted bribes or engaged in other corrupt activity relating to the selection of third-party providers. The review required FTI Technology’s team to determine whether there was evidence to substantiate the whistleblowers’ allegations and whether other conflicts of interests or employment violations had occurred within the group in question. In addition to the highly sensitive nature of the review, there were challenges with preserving or obtaining certain potentially relevant communications. There was evidence that the suspected bad actors within the organization had used ephemeral communications that could not be recovered to support the investigation.

Our Role

For nearly three years, FTI Technology has been supporting the client with regular compliance monitoring, lookbacks and internal investigations of randomly-selected business segments or in response to whistleblower reports. FTI Technology’s compliance and analytics experts provide fast, thorough and high-value fact-finding, analysis and reporting through several expert-led, technology-driven offerings. Solutions delivered include:

  • Customized, proactive compliance program and communications monitoring to identify suspicious activity, answer key questions about it and uncover information to support or guide follow-on investigations.
  • Creation of a work product database that is used in ongoing investigations to more rapidly identify similar wrongdoing and predict issues in future monitoring projects.
  • Real-time insights to inform proactive steps. In the investigation into the business department suspected of nepotism and corruption, this included identifying that ephemeral messaging tools were in use within the organization, so the compliance team could quickly take steps to remediate the unsanctioned use of such tools and implement measures to prevent further use.
  • Find Facts Fast researchers to leverage a variety of analytical tools and workflows that establish an understanding of information within specific document sets of interest.
  • Story Development, including fact memos and narratives and chronologies that facilitate deeper understanding of compliance issues, events and key players.
  • Comprehensive summaries of risk areas relating to quarterly reviews, specific business segments and whistleblower reports.
  • Proactively identify vulnerabilities to prevent future, ongoing investigations or regulatory violations.

Our Impact

FTI Technology continues to work with the client to develop analytics-led solutions for compliance monitoring and internal investigations. These efforts have enabled the client to quickly respond to whistleblowers and internal violations and provide timely and informed insights to leadership about regulatory and operational risks.

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Detailed quarterly reporting with comprehensive summaries of risk areas, upon which the compliance team and leadership can take responsive, remedial and strategic actions.

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Analytic workflows provide budget predictability, efficiency and hundreds of thousands of dollars in cost savings for proactive and reactive compliance reviews across millions of documents and numerous locations around the globe.