The Department of Justice (DOJ) requires visibility into how 3rd party business is conducted with each partner, who controls the relationship, and how your organization responds to risk. Catelas Compliance Control and Risk Oversight Software is the first solution that cost effectively puts the Compliance Officer in control by providing unprecedented insight into how business is conducted overseas.
Catelas’ patented software solution automatically provides evidence of Compliance with a real-time view of your entire company, who you do business with and all the players involved. Our software leverages the most advanced behavioral algorithms & relationship analytics to create a user-friendly Relationship Database. This database gives you the tools to automate processes such as on-boarding, training program maintenance, periodic review reports and much more. Your people can do more because we automate much of what they do, leaving them to focus their efforts were the risk is greatest.
Best Practices in FCPA Monitoring
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Case-Study – Uncovering risk before you on-board it
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Understanding who you work with
Relationship Monitoring- Catelas advanced patented algorithms were specifically developed for Relationship monitoring. The software automatically creates a live Relationship Database by tapping into the log files created by email systems such as Microsoft Exchange and Lotus Notes. This Relationship Database details & ranks all the people & relationship networks that describe how your company does business with each 3rd party, across each region globally. With regards to privacy, concerns are met as only people & relationships are derived from the email logs – no email content or dates are actually collected.
Privacy
The Relationship Database is in fact very similar to a Customer Relationship Management (CRM) system except that it is focused solely on your 3rd party networks and the names of the people involved are automatically populated rather than requiring your employees to populate it.
Relationship monitoring then leverages social network analysis and behavioral science to analyze this relationship database. The process is automated, gaps are plugged, and most issues are automatically remediated.
The Catelas Compliance Control and Risk Oversight Suite – 4 Modules
The Compliance Suite gives you the tools to automate processes such as on-boarding, training program maintenance, periodic review reports and much more. Your people can do more because we automate much of what they do, leaving them to focus their efforts were the risk is greatest. You can deploy one, a few or all the four modules detailed below.
MODULE 1: ON-BOARDING & DUE DILIGENCE
MODULE 1 – ON-BOARDING
Enrich the On-boarding Process through the expanded identification of the key people representing each 3rd Party. This extended list automatically populates existing questionnaires. Including these key people representing the 3rd party, but who are below ‘officer’ level, represents a significant extension of the risk assessment process prior to on-boarding that risk. This improved risk assessment is automated and consequently has no resource impact whatsoever.
Enrich the Due Diligence Process: – when required, the due diligence process typically involves internal resource, and external consultants and services with the associate measurable cost. Catelas 3rd Party Relationship reports are prepared in minutes and provide the due diligence team with unprecedented insight into how your company connects to the third party, the key players and how they do business. This depth of knowledge is currently assembled manually (if at all), incurring significant time and cost. Catelas provides detailed reports automatically and at the touch of a button, creating greater efficiencies and improved accuracy from the due diligence process. Again this Catelas function is automated and consequently has no resource impact whatsoever.
MODULE 2: TRAINING PROGRAM MAINTENANCE
MODULE 2 – TRAINING PROGRAM MAINTENANCE
Expand Training and Certification– many companies currently certifies only one person at each 3rd party, a person nominated by the 3rd party themselves. Is this the right person to train? are they really the persona tasked with managing your business on the ground. Catelas will enable you to automate the process for expanding that certification (and even training) to all of the key participants. In light of the Morgan Stanley case, communication, training, and certification is very important to the DOJ. Catelas expands your company’s communication without generating a large resource burden.
Self-healing Program Maintenance – Catelas automatically and periodically identifies all new 3rd Party employees which have not completed the required training & certification (Catelas also identifies internal resources whose roles have changed and therefore require additional training). A report is automatically generated and emailed to the 3rd party sponsor requesting remediation. A follow-up email is sent within a month and a Regional Training Gap report sent to Compliance within 2 months. Again this Catelas function is automated and consequently has no resource impact whatsoever.
MODULE 3: PERIODIC REVIEW PROCESS
MODULE 3 – PERIODIC REVIEW PROCESS
Enrich the Periodic Review process: – Catelas automatically creates region wide reports for all 3rd parties subject to annual review within a current year. Reports shall include: -
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Company Relationship Ranking, detailing current regional rank & change since on-boarding
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Training gap report – listing all non-compliant internal & 3rd party employees
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Key people list with 3rd party & who they connect with in your company
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Relationship map – details how 3rd party connects & interconnects to your company, collaborative networks & key relationships
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Table showing roles & responsibilities for all key people
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Employee risk report for all internal employees, listing breaches of policy rules
Targeted, 3rd Party Alerts – Catelas, utilizing a rules-based engine, automatically identifies specific employee ethics & conduct policy breaches & company level changes of significance. Graded alerts are generated creating red flags only when a combination of conditions exists and when Compliance needs to be made aware. All other alerts dovetail and populate the Periodic Review report and are address during program maintenance, unless conditions change such that the alert becomes a red flag.
MODULE 4: INVESTIGATIONS
MODULE 4 – INVESTIGATIONS
Internal Investigations: Catelas is used extensively for investigations by the leading forensic consultancies and large corporations. Catelas delivers more actionable intelligence in the first 30 minutes than previous processes provided in days or even weeks. Catelas Identification allows the investigator to identify the people involved, how they connect and who matters – without collecting any data – and Catelas Early Case Intelligence isolates the key conversations in 1/10th of the time and without relying on keywords. Accessible, accurate information leads to better decision making, better collaboration, and accelerated outcomes.
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