Defensible Data Driven Compliance Program

Case Summary

Compliance monitoring and evaluation conducted for a global mineral and mining company in response to a DOJ investigation on an alleged FCPA violation.
Focus on Vendor 360, procure-to-pay module

$20+ billion in payments data analyzed using 100+ behavioral tests and algorithms

100% of payments and supply chain data processed

Challenge

A global mineral and mining company was under DOJ investigation due to an allegation of FCPA violation. The company needed to implement a mature compliance program that demonstrated effective internal compliance controls and monitoring, particularly around interactions and payments to third parties.

“I needed a cost-effective transaction monitoring tool which would identify high-risk transactions, flag potential control weaknesses, improve over time through machine
learning, reduce the number of false positives reviewed by the compliance team and be user-friendly in terms of configuration and visualization.

konaAI delivers on all counts, and I was very pleased with the choice we made.”

Client Testimonial

Solution

When the company and its counsel approached konaAI, we knew the compliance analysis process would require a comprehensive review of the of the organizational financial activities. Working with the Chief Compliance Officer and General Counsel, konaAI’s Vendor 360 module was utilized in extracting and evaluating over $20 billion payments data with all the payments and supply chain data being subject to 100+ tests and behavioral algorithms.

Working with the Chief Compliance Officer and General Counsel, konaAI’s Vendor 360 module was utilized in extracting and evaluating over $20 billion payments data with all the payments and supply chain data being subject to 100+ tests and behavioral algorithms.

The company and its counsel

Reviewed the top 100 riskiest transactions.
Trained konaAI’s predictive model using
previously identified high-risk
transactions to identify statistically similar transactions.
Remediated high-risk payments before disbursement.

Results

Predictive Modelling
Utilized in Remediating
High-risk Payments

konaAI Analysis Shared with
DOJ, 45% Sentence Reduction

Recognized as 2024 Compliance Program of the Year!

The company’s commitment to compliance and its partnership with konaAI had remarkable outcomes:

No Prosecution – Seeing the company’s cooperation and remediation efforts, the DOJ decided against prosecution or independent monitoring; reduced sentencing by 45%!
DOJ acknowledgement – The DOJ specifically highlighted some of the extensive remediations:
- Carrying out a root-cause analysis of the misconduct
- Making significant investments in organizational compliance personnel, compliance
  testing, and monitoring.
Recognized by Compliance Week as “Compliance Program of the Year” for high quality of the compliance program with recognition of the use of data-driven compliance.

By partnering with konaAI, the global mineral and mining company was able to leverage advanced analytics and predictive modelling to strengthen their compliance infrastructure. Their proactive approach and commitment to compliance helped resolve a high-stakes investigation with the DOJ.

Sahil sharma