Webclass 35: Travel & Expense – a quick win to get started with data analytics for audit

Q1. Is it dangerous for a company to give travel tickets to government officials in order to ensure that you get a sales license in the country?

Yes because you could get a very high-value fine from the local government or from the SEC, especially if it is in China, you could get a fine under the China Anti Corruption Law, which does not accept "facilitation payments" as a reason for providing gifts in the form of travel to government officials.

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No, it is ok to provide gifts if it is for facilitation payments.

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Q2. If you get a fine from the FCPA, will the SEC give you action points for internal controls that you are obliged to follow up on?

Yes, for example, the SEC gave actions to Bruker, following their fine for their China operations, which included ensuring that they "establish and ensure compliance with approval processes for non-employee travel".

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No, the SEC considers that it is up to the governance of the company to decide on which internal controls are best for the business.

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Q3. If it is an agency (such as a sales agency, distribution agency or travel agency) that is giving gifts or travel to customers or government officials, without your company’s knowledge, is your company still liable under the FCPA?

Yes, especially if it can be shown that your company gained an unfair commercial or strategic advantage thanks to the actions of the third-party agency. For example, in the GSK case, the company received hefty fines due to its third-party travel agency providing travel to government officials.

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No, because the action was done by the third-party and not under the control of your company.

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Q4. Can employees of your company go to jail if a third-party agency gives bribes to other third parties that can be shown to provide a commercial or strategic advantage to your company?

Yes, in the GSK case, the C-level employees and management received between 2 to 4 years of imprisonment in China.

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No, local employees cannot be sent to jail due to the actions of third-party agencies.

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Q5. Does the SEC consider T&E audits to be an essential part of a fraud prevention program?

Yes, for example, the SEC gave actions to DIEBOLD to "Carefully monitor travel and expenses to avoid abuses" following the 48M USD fine for corrupt practices.

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No, the SEC does not consider T&E to be of significant importance for preventing corrupt practices.

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Q6. Why is it not sufficient for auditors to only look at the data in the T&E system when doing a T&E data audit?

Because employees may make manual journal entries for T&E rather than going through the T&E system, so it is also necessary to screen the general ledger for T&E transactions and compare these to the T&E system, to isolate all journal entries for T&E that were not entered in the T&E system, and so to also include these journal entries in the audit population.

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Because the auditors should take a sample and review the receipts to ensure that the VAT values are entered correctly.

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Q7. Which other data sources could you compare your T&E data to, to ensure that your T&E does not relate to employees that are not in the company?

Active Directory logs

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List of employees on the payroll

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Building access logs

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List of employees on SI

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List of holiday requests

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List of employees on personnel list

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List of employees that have left the company (starters and leavers) or "Actions" table in SAP (PA0000)

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List of employees in the T&E system

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Q8. How does a scatter plot that shows the expense value versus the percentage difference compared to the average for the expense type, help to identify unusual expenses?

Because it shows you which employees have an unusual expense value compared to the rest for a particular expense type.

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Because it shows you which employees should not have entered expenses.

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Q9. If you are doing a duplicate test on expenses, why is it not particularly interesting to only take expense type and value as the criteria for the duplication?

Because the employee might have the same hotel room for many nights or the same taxi ride for many days and this would give you a lot of false positives.

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Because the value could be different for some of your cases.

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Q10. In which table in SAP can you find the expense type description?

T706B5

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PTRV_SHDR

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Webclass 35: Travel & Expense – a quick win to get started with data analytics for audit

Webclass 35: Travel & Expense – a quick win to get started with data analytics for audit

admin June 9, 2026

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