Webclass 58: Fraud, FCPA and Investigations

Q1. What does Galina say is the most effective prevention?

Employees that know that they are being watched

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Data analytics

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Q2. In the example that Galina gave, what did she say helped to improve management engagement and awareness for fraud prevention?

Proactive data analytics to detect possible issues and then interviewing and follow-up with employees + regular reporting

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Using data analytics to detect issues and then reporting directly to top management of the initial results

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Q3. Should the whistleblower hotline be anonymous?

Yes – but there can also be an open door policy

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No – employees should be accountable for the information that they communicate

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Q4. In the example given by Galina, did management recognise the importance of the use of data analytics from the start?

No it took some time for them to understand that the data analytics were assisting them and helping them to reduce unknown losses

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Yes management were fully aware of the advantages and it is thanks to their sponsorship that the project was possible

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Q5. Is it necessary for each member of your team to know about fraud and data analytics?

No- if you have some members that are good at fraud and some that are good at data analytics, you can pair them

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Yes – to be effective, all team members must be strong in both data analytics and fraud

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Q6. What does Galina say is one of the most important checks for new employees/employees that handle cash?

Background checks

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Check the salary level compared to the pay scale

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Q7. Is it common to be able to conclude at the end of an FCPA audit?

No- it is common to submit the information to legal counsel and the audit committee – quite often the results are grey and require further investigation

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Yes – at the end of the FCPA audit, it is essential that all conclusions be confirmed

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Q8. According to Galina, can audit be based on analytics alone?

No – audit is a combination of interviews and analysis

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Yes – for some audits we can solely use data analytics to go quicker

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Q9. What two methods does Galina mention for looking up suppliers?

Treasury.gov and Google Boolean

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Python checks on supplier name and verification of tax codes

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Q10. If you use an “agent” for commercial/marketing tasks and this agent has a bank account in the US and also carries out some bribes to win some work that your company benefits from, could you be liable under the FCPA?

Yes

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No

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Webclass 58: Fraud, FCPA and Investigations

Webclass 58: Fraud, FCPA and Investigations

admin June 9, 2026

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