how corrupt is your international business?

Copyright © 2011 Catelas Inc. All rights reserved FCPA Compliance – Apr 2011

How corrupt is your international business?

FCPA compliance


The spotlight is on

2010: 50 individuals had been charged and nearly $2 billion collected from FCPA2005: 5 individuals and roughly $16.5 million collected

2009 20100

0.51

1.52

FCPA$ Billions

• Huge press exposure, both USA FCPA & UK Bribery Act

• Criminal liability for company executives

• SEC ‘whistle-blower incentives


The real cost of FCPA violations

ITT$12B total revenues; 40,000 employees$5B in government contracts; F500

FCPA – China payments case

DCAA audit $0.5M

Fine $1.7M

Legal Fees $4.0M

Post-case monitoring $1.5M

TOTAL COSTS $7.7M

Estimated Costs

Press reports show a fine of $1.7M but the real cost to ITT could easily be in excess of $10M (not including business opportunity cost)

ITT was fined $1.7M for allegedly paying Chinese officials for the sale of water pumps. They were accused of paying $200k in bribes for business worth $4M and after-tax profits of $1M


The ProblemHow responsive are you?

Are your investigations something like this?

Slow, disruptive & ineffective

Any Investigation ... • Involves many organizations, languages• Collection alerts organization (leads to

cover-up)• Who is key? Who have we missed?• Time is money – the longer this drags on,

the more it costs


The ProblemA new paradigm

Faster, smarter, more effective investigations• Insight into entire company (not just who you think might be involved)• Non-disruptive (investigate before collection and interviews)• Provide Case Intelligence within days not weeks • Prioritize most important investigations

So you can…• Investigate quickly & conclusively• Save significant time and money in

collections and review


Typical FCPA deployment

Intelligent Discovery(Log File analysis)• Before Collection:…• Identify who is involved (from HQ)• Provide Early Case Intelligence report• Assess case importance• Define case strategy

Early Case Analytics(Native email analysis)

• Deployed on laptop or remotely accessed server

• Prioritized review of communications between key custodians

• Key word analysis and network maps• Create case report for executive

review

Multiple Deployments


Relationship Forensics

Be ahead of the game!

Catelas…• Anti-corruption ‘peace of mind’• Deal with investigations quickly

& effectively• Avoid the big fines and press

headlines


Live DemoDemo


Thank You

Robert Levey978 996 [email protected]

mailto:[email protected]

http://www.catelas.com/

how corrupt is your international business?

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