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Anti-Bribery Compliance

CaseWare Monitor Applications


Suspicious Vendors

  • Identify unauthorized vendors – monitor for vendors with master data changes created and/or approved by an unauthorized employee
  • Identification of vendors where alternate payee names have been alternated multiple times within X days
  • Identify vendors with multiple changes to bank account number within a specified time period
  • Identification of frequent use of one-time vendor arrangements

Suspicious Procurement Activities

  • Identify payments for large amounts without proper documentation
  • Identify cumulative payments for two or more transactions that were approved by Same Employee to the Same Vendor exceeding or within a Percentage below the Authority Limit
  • Identification of bonuses or commissions of unusual quantity or timing
  • Identification of frequent use of one-time vendor arrangement
  • Identification of payments made following manual overrides in the system
  • Identify purchase orders where the total payment amount was greater than the total purchase order amount
  • Identify invoices where the invoice receipt amount is greater than the Goods Receipt amount

PEP/OFAC Sanctioned Lists Matching

  • Identify expense transactions where the vendor name (and attendee name in the case of meals) closely matches a name on the OFAC/GSA/PEP/KYC/CFT lists or other supplied lists of names

Suspicious Travel & Expense Activities

  • Identify charitable contributions or entertainment expenses to organisations with government affiliations
  • Identify multiple gifts to a single individual
  • Identify unauthorised Travel & Expense cards
  • Identify Segregation of Duties violations: e.g. Submitter same as Approver

Suspicious General Ledger Activities

  • Identify invalid or suspicious journal entries to temporary accounts
  • Identify payments made following manual override in the system such as direct manual postings to the GL
  • Identify suspicious journal entry bookings at unusual times.
  • Identify adjustments to accounts inactive for more than X days

Suspicious Third-Party Activities

  • Monitor suspicious activities to 3rd party providers e.g. illegitimate vendors used by approved vendors
  • Use of new lawyer / accountant / agent / customs agent / consultant with no prior relationship
  • Identification of payments classified as government expenses

High Risk Transactions & Key Word Matching

  • Missing descriptions or suspicious key words for payment transactions such as “gifts”, “services rendered”, “consulting”, etc.
  • Identify Key Words or Innuendos in any language or dialect (Forbes top bribery keywords)
  • Identify transactions to vendors or individuals in high risk jurisdictions
  • Identify high volumes of cash transactions
  • Identify payments made from out-of-country bank accounts or sent outside the country of operation
  • Identify employees with more than a defined number of even-dollar cash expense transactions above a specific amount threshold within a specified time period

Applications , CaseWare Monitor



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