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Anti-Corruption Transaction Testing

Anti-corruption transaction testing that runs each payment, expense and agent invoice through the red-flag rules, and hands counsel each hit with its documents and one question.

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From the red-flag queue to the findings report ↓
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The problem

Thousands of hits, a few hundred tested, and the split payment found last

The audit committee wants to know whether bribes went through the books. The forensic team pulls the ledger, payables, expense reports and agent invoices, runs a handful of queries and gets thousands of hits back, most of them false positives. Each one is cleared on its own: find the contract, the invoice, the bank line and the approval email, then decide.

So the review falls back on a sample of a few hundred lines, and forensic accountants charge by the sample. The payments that matter sit in plain sight: a sum split to stay under one approver’s limit, a broker paid to an account its contract never names, a clearance invoice with no container behind it. Found late, they cost the company the credit it earns for finding and reporting the facts first.

Built forInvestigations partnersAnti-corruption counselForensic accountantsCompliance officers

The Problem Today

Bribery hides in ordinary ledger lines, and most reviews still test a sample by hand.

$25M
most a company is fined per false-books violation published
$2M
most a company is fined per anti-bribery violation published

Pulled from four places today

  • Ledger
  • Invoices
  • Bank lines
  • Emails
  • Thousands of false positivesEach one checked against four documents
  • Found late, credit lostDisclosure credit rewards finding the facts first

The Solution

  1. All lines pulled and testedLedger, expenses and agent invoices against each red-flag rule
  2. Hits ranked by riskSplit payments, vague services, accounts the contract never names
  3. Each hit explains itselfContract, invoice, bank line and email, plus the one question to ask
  4. Counsel decides each hitClear, escalate or ask with a reason; the partner decides disclosure

Built-in controls

  • Questions reach the business only after approval
  • Rule authors never clear their own hits
  • Matter data is never used to train a model

What You Get

The audit committee gets a findings report with each sentence cited, and disclosure is decided early.

≈60%
fewer reviewer hours spent clearing false positives our estimate
  • One question per hitThe business is asked only what clears or confirms it
  • Workpapers that fill themselvesSamples, attributes and citations as the testing runs
  • Disclosure decided earlyThe partner sees each item with its chain of documents
From ledger to findings

How anti-corruption transaction testing turns 1,212 hits into 9 decisions

The review moves from a ranked queue through the evidence chain and two samples to the report the partner decides disclosure on. Each feature below is one step of it.

  1. 01Red-flag queue

    A red-flag queue that tests every line and ranks the open hits

    How it works

    • 486,000 lines tested; the funnel shows 1,212 hits: 1,018 cleared with a reason, 73 escalated, 121 open
    • Open hits ranked by risk, each with its rules, documents cited and the agent’s proposal
    • The selected hit shows its chain of documents and three buttons: clear, ask or escalate

    Anti-corruption counselOpens on the riskiest open hit with its documents already pulled, and no spreadsheet of thousands to sort.

  2. 02The week the rule saw

    A week chart that shows a split payment against the approval limit

    How it works

    • A day-by-day chart of the week the rule saw, with the approval limit drawn across it
    • Three payments of $9,900 in 4 days, each 1% under the $10,000 limit, one approver
    • The risk score built rule by rule: +34 for the split, 96 in all
    • Only 6 of the 1,212 hits carry four rules or more

    Anti-corruption counselSees why a payment ranks first, and that the person who asked for it approved each part, before opening a single document.

  3. 03The evidence chain

    An evidence chain that writes the mismatch on the link between documents

    How it works

    • Contract, invoices, bank line and approval email, each quoting the passage that matters
    • Between each pair, what does not agree: no container on the invoices, another account
    • Beside it, the same payee’s three-year totals: 17 hits in all

    Anti-corruption counselGets the four documents she would have pulled herself, already read against each other, with the one question that would settle the hit.

  4. 04Question to the business

    One question to the business, drafted on escalation and held for approval

    How it works

    • Escalating takes a written reason, kept in the decisions log and the workpaper
    • The question goes to the country finance lead through the client’s general counsel
    • Beside it, what would clear the hit and what would confirm it
    • Nothing leaves until counsel approves it

    Anti-corruption counselAsks the business one precise question per hit, knowing before it goes which answer clears the payment and which confirms it.

  5. 05Red-flag rules

    Red-flag rules with thresholds, weights and a back-test for every change

    How it works

    • Eleven rules, escalation rates from 21.2% for an official match to 2.4% for a cash advance
    • A proposed change is back-tested on 3 years before counsel rules on it
    • The analyst who proposes a change cannot approve it or clear the hits it removes

    Forensic data analystTunes the rules on evidence: raising the cash-advance floor from $250 to $500 removes 61 cleared hits and loses no escalated one.

  6. 06Third parties

    A heat grid of the riskiest third parties against the rules they hit

    How it works

    • 38 agents, brokers, distributors and consultants, with the 12 riskiest shown
    • For the selected party, what was paid against what its contract supports
    • The customs broker: $318,450 paid, $224,590 supported

    Forensic data analystSees which brokers and distributors carry the pattern, and how much went out with no contract term behind it, without building a pivot table.

  7. 07Questions to the business

    Business answers read against the chain, with a proposed reading for counsel

    How it works

    • Tiles count questions drafted, sent, answered and awaiting approval: 31, 25, 15 and 6
    • The agent proposes whether the answer clears the hit; counsel decides
    • Receipts covering 57% of the cash advances, four naming another payee, read as not clearing

    Anti-corruption counselKnows which answers close a hit and which keep it open, with each receipt already set against its advance.

  8. 08Statistical testing

    A statistical sample of unflagged lines, tested attribute by attribute

    How it works

    • 400 lines, 100 per country, drawn at random, with the seed logged so the draw repeats
    • Six attributes on each: approver, invoice, contract or order, service, vendor account, receipt
    • 2 exceptions in 400, both missing receipts, neither a bribery indicator
    • Upper error rate 1.6% at 95% confidence, against a tolerable 5%

    Forensic data analystCan show that the lines the rules passed are clean too, in a workpaper that fills as each item is tested.

  9. 09Items for a disclosure decision

    A draft findings report with the items for a disclosure decision

    How it works

    • The findings report drafted with a citation on each sentence
    • Nine items from four countries, $684,200 in all, from $29,700 to $212,400
    • The timeline puts the draft at week 4, where the usual review reaches about week 12

    Investigations partnerDecides disclosure early, on items she can trace back to the ledger line, the contract and the email behind each one.

Hit 1 split $29,700 three ways, and the contract says otherwise

The top-ranked hit, document by document, as the chain reads it.

RecordWhat it shows
Contract, clause 4.1$185 per container; duties at cost against customs receipts
Contract, clause 6.2Pay only the account named in Schedule B, ending ·2207
Three invoicesExpedited clearance, $9,900 each, no container numbers
Payment runsThree wires to an account ending ·4410, one approver each time
Approval email, Sunday 21:47Pay it as three separate payments this week, to the new account
Brokerage for the shipment14 × $185 = $2,590, invoiced and paid separately
Three years with this broker$318,450 paid; the fee schedule supports $224,590
No container behind it$93,860
Six more screens

The cited page, the reason box and four more screens from the review

Where the hits are checked, decided, logged and set.

The bank line, at its pageOne click opens the payment runs behind the chain: three wires of $9,900.00 to the new account, each approved by the same person.
A reason before it movesEscalating hit 1 opens a reason box, written from the chain, that lands in the decisions log and the workpaper. Counsel edits it or keeps it.
Sixty picked by riskFive payments to each of the 12 highest-risk third parties: 7 exceptions in 60, all escalated, and each one already a rule hit.
Who decided, and why1,018 cleared and 74 escalated, each by counsel with a reason. Agents’ actions sit beside people’s, and the count decided by an agent reads 0.
Limits for each subsidiaryOne-approver limits in four currencies, the 7-day split window and a hospitality limit of $150 a person. A change is saved as a proposal.
The queue after the escalationEscalated now reads 74, open 120, and the disclosure tile 9 at $684,200. Next in line: a commission billed at 14% where the agreement allows 6%.

A 14% commission, a mayor’s spouse and a retainer paid before its contract

Four of the nine items now waiting on the partner’s disclosure decision.

A commission at 14% against 6%

A distributor billed its commission at 14% of sales where the agreement allows 6%. The excess, $212,400, is the largest item for a disclosure decision.

A donation with a trustee link

$50,000 went to a municipal foundation. The answer sent back a thank-you letter signed by a trustee who is the mayor’s spouse, so the agent read it as needing follow-up.

Receipts that miss the advances

Nine receipts totaling $21,300 came back for $37,500 of cash advances to a customs agent. Seven are dated after the advance was settled, and four name another payee.

A consultant paid before its contract

A permit consultant drew a retainer 19 days before its agreement was signed, for permit advisory services.

Who does the legwork

Six agents read the ledger; counsel and the partner decide every hit

From the ledger pull to the draft report, every agent stops short of a call on a payment.

Ledger puller

Pulls ledger, payables, expense and agent-invoice lines, and maps each payee to a third party.

  • Never changes a ledger record
Official matcher

Matches payees, attendees and company directors against official lists and ownership records, with a match score.

  • Never decides that someone is an official; a person confirms
Contract matcher

Matches each invoice to its contract terms and to proof the service was delivered.

  • Never assumes a service happened without a document
Red-flag scorer

Tests each line against the rules and ranks the hits by risk.

  • Never clears or escalates a hit
Evidence chain agent

Assembles each hit’s contract, invoice, bank line and approval email, cites the passages and proposes the one question.

  • Never sends a question
  • Never contacts an employee
Workpaper agent

Draws the samples, fills the testing workpapers and drafts the findings report with a citation on each sentence.

  • Never writes a conclusion counsel has not approved

Before anti-corruption transaction testing runs on a live ledger

What is anti-corruption transaction testing?

Anti-corruption transaction testing runs a company’s payments, expenses and third-party invoices through red-flag rules to find possible bribes. This solution tests the whole population instead of a sample, ranks the hits by risk, and hands counsel each one with its contract, invoice, bank line, approval email and the one question that would clear or confirm it.

What bribery red flags does it test for in third-party payments?

Split payments just under an approval limit, round sums, vague services, and accounts the contract does not name or that sit offshore. It also looks for payees who match an official, commissions above contract, hospitality to officials, cash without a receipt, early payment, duplicate invoices and weekend manual entries.

Who decides whether a hit is cleared or escalated?

Anti-corruption counsel, with a written reason each time. The agents propose clear, escalate or ask, and the decisions log shows that none of them decides. The analyst who tunes a rule cannot clear its hits, and the investigations partner alone decides disclosure.

Does anything reach the client’s employees without counsel?

No. An agent drafts each question from the hit’s chain of documents, counsel approves or edits it, and it goes through the client’s general counsel. Agents do not contact employees.

Why sample at all when the rules test the whole ledger?

A statistical sample of lines no rule flagged shows that the passed lines are clean too, and puts an upper error rate on them. A judgmental sample of the riskiest third parties checks that the rules catch what a reviewer would pick on judgment.

How is privilege kept on the work?

Screens and exports carry the privileged and work-product marking, the names of employees not yet interviewed are masked in the draft report, and each read and decision is logged.

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Find the split payment
while the credit is still yours.

We’ll walk you through the queue, the evidence chain and the draft report on a matter your team has already closed.

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