Assess whether a referral to counsel is warranted (397d87)

Situation

Related-party customer map arrived with an FCPA agent-payment spike in one country for FCPA investigation lead. That is a Forensic Accounting Related-Party and Corruption Risk decision on a referral to counsel is warranted in a construction contractor on percentage-of-completion.

Decision

FCPA investigation lead in a construction contractor on percentage-of-completion must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using related-party customer map after an FCPA agent-payment spike in one country.

Hypotheses to test

• The population in related-party customer map is the one an FCPA agent-payment spike in one country named, so Remove access or reverse the item follows for this Related-Party and Corruption Risk file.
• The population in related-party customer map is adjacent only to an FCPA agent-payment spike in one country; Temporary compensating control is the honest Forensic Accounting call.
• A construction contractor on percentage-of-completion already contained an FCPA agent-payment spike in one country before related-party customer map arrived; no new Related-Party and Corruption Risk path.
• Provenance on related-party customer map after an FCPA agent-payment spike in one country is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Separate a close-process miss from a qualitative SAB 99 issue in a construction contractor on percentage-of-completion.
• Reconstruct vendor, journal, or inventory lines in related-party customer map through the window opened by an FCPA agent-payment spike in one country.
• Trace approval, SoD, and related-party links that related-party customer map actually shows.
• For this Forensic Accounting Related-Party and Corruption Risk file, read related-party customer map against an FCPA agent-payment spike in one country and write the one fact that would move a referral to counsel is warranted for FCPA investigation lead.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Forensic Accounting / Related-Party and Corruption Risk packet (related-party customer map after an FCPA agent-payment spike in one country). The follow-on Related-Party and Corruption Risk action is what FCPA investigation lead does next: implement the option, assign an owner, and log the missing fact.