FCPA / ABC Compliance Analytics

Analytics Test Details

Regulations can change frequently, and a flexible application that enables you to be current can reduce the cost of compliance through the timely detection of potential issues

PEP/OFAC Sanctioned Provider


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 lists 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 / Payee Details Identify vendors with more than one change to bank account number or payee within a specified time period.
Unauthorized Vendor Data Changes Identify vendors with master data changes created and/or approved by an unauthorized employee.


Unauthorized Vendor Data Changes Identify vendors with master data changes created and/or approved by an unauthorized employee.

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

Manual Payments Look for manual overrides for payment processing, unusual use of miscellaneous / one-off vendor accounts.

Unusual Journal Entries Identify unusual journal entries (e.g. No clear business purpose, Abnormal Debits/Credits, Benford’s Law)

Phantom Employees Identify Employees that may not be true employees.

Individual Gifts Identification of multiple gifts to a single individual
Government Official Entertainment Identification of entertainment of government affiliated individual
Segregation of Duties Identification of Segregation of Duties violations: E.g., Submitter vs. Approver (Travel & Entertainment)

Unauthorized T&E Cards Identification of unauthorized Travel & Expense cards
Charitable Donations Identification of charitable contributions to organizations affiliated with the government


Bonuses or Commissions Identification of bonuses or commissions of unusual quantity or timing

One Time Vendors One-time vendor analysis: Identification of payment more than the threshold value

Cash Checks Identification of checks made to “cash”

Cash Transactions Metric Identification of high volume of cash transactions

Out of Country Bank Accounts Identification of payments made from out of country bank accounts or sent outside the country of operation

Non Relationship Use Identify Use of new attorney / accountant / agent / consultant with no prior relationship

Manual Overrides Identification of payments made following manual overrides in the system

Government Payments Identification of payments classified as government expenses

Frequent Use One Time Vendor Identification of frequent use of one-time vendor arrangements

Non Reference Document Payments Detect payments made without reference documents

Suspicious JE Identify invalid or suspicious journal entries to temporary accounts

Unusual Time JE's Identify suspicious journal entry bookings at unusual times or flip-flopping

Account Adjustments Identify adjustments to accounts inactive for more than X days


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