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EXPERIENCE

COMPLIANCE

Global Management Consulting Company

Independent Compliance Review

Guidepost Solutions provides comprehensive risk assessments specifically tailored to the company’s significant government contracting services. Through the implementation of anti-corruption controls, including automated controls for pay-to-play and conflict of interest issues related to former government employees, the company effectively tracks employee campaign contributions and conducts enhanced vetting of former government employees.

FCPA Compliance

Guidepost Solutions assisted the company with conducting a comprehensive health check of its FCPA program. This engagement involved several separate work streams and focused primarily on their business intermediaries and business development agents.  These work streams included:

  • Assessing the company’s current FCPA program.
  • Developing an in-house low and medium risk due diligence research program.
  • Training staff in foreign countries to operate the research program.
  • Drafting a procedural manual on how to conduct research.
  • Upon deployment, reviewing weekly reports and an annual report.

The first phase was an assessment of their current FCPA program, questionnaires and primary on-line tools.  For several months, Guidepost Solutions performed an “apples to apples” review of the external reports the company purchased for their various levels of due diligence and conducted an independent report to compare the results.  The results identified that the external provider had missed several key findings and a price analysis revealed the cost of the reports to be very high compared to the scope of review.  For example, a low-level due diligence report cost several hundred dollars and it mainly contained results from an open source internet search using a fixed search string with adverse media terms.

Guidepost Solutions also reviewed the company’s internal and external FCPA questionnaires which were being loaded into a third-party portal to calculate an initial risk rating. This tool was managed by the company’s off-shore team conducting some of the preliminary database checks for the initial risk rating.  This team would then use one of three different vendors for the actual due diligence reports.

Based on recommendations and input provided by Guidepost Solutions, the company built its own FCPA portal to manage the questionnaires and the initial risk rating. Additionally, the company decided to conduct their own low and medium risk due diligence research in-house by building a competency center off-shore.  Guidepost Solutions developed this program, trained the off-shore internal team on-site, and assisted with the procurement of a research tool. The training focused on how to conduct research and use the systems and tools for reporting. Guidepost Solutions also established a reporting methodology and drafted the initial desktop procedure manual to be used when conducting research.

As a follow-up to the deployment of the new team, Guidepost Solutions conducted weekly QA reviews for three months, provided feedback to the team, and conducted an annual QA review at the one-year anniversary. Since the deployment of this team, the company has expanded its scope of reviews to include potential mergers and acquisitions and other ad-hoc research needs.

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