Compliance Tests

Today’s global business environment has created highly international, decentralized


Individuals often operate in remote countries where bribes and payoffs have

historically been a routine part of conducting business.

When language, culture and traditions vary so widely, keeping close tabs on international operations can be extremely challenging.

When it comes to bribery provisions, data analytics are the most powerful way to validate the completeness and accuracy of books and records.

Continuous monitoring provides assurance around the effectiveness of internal controls and pinpoints transactions that appear suspicious.

  • Providers Name Matching

Identify expense transactions where the vendor name (and attendee name in the case of meals) closely matches a name on the OFAC/GSA list or other supplied list of names (e.g. PEP list, prohibited vendors)

  • Suspicious Key Word Matching

Identify payment transactions containing suspicious words in identified fields (e.g. description or comments fields) such as: gifts, services rendered, facilitation, cash

  • Transactions with High Risk Countries

Identify payment transactions to vendors or individuals in high risk countries

  • Repeat Even Dollar Transactions

Identify employees with more than a defined number of even-dollar cash expense transactions above a specific amount threshold in a specified time period

  • Flip-Flop Bank Accounts

Identify vendors with more than one change to bank account number within a specified time period

  • Unauthorized Vendor Data Changes

Identify vendors with master data changes created and/or approved by an authorized employee.

  • Overpaid Purchase Orders

Identify purchase orders where the total payment amount was greater than the total purchase order amount.

  • Invoice Receipt Greater than Goods Receipt

Identify Invoices where the invoice receipt amount is greater than the Goods Receipt amount

  • Flip-Flop Payee Names

Identification of vendors where alternate payee names have been flip-flopped within a specific time period

  • Split Payments

Identify cumulative Payments for two or more transactions approved by same Employee to the same Vendor that exceeds or is within a Percentage Below Threshold of the Authority Limit.


At Pathfinders, we explore more on Internal controls; please join us, and share your views. Pathfinders love enriching.


Suresh Shah, M.D., Pathfinders Enterprise

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