FCPA

Applying Work Discovery to Your FCPA Compliance Program

on March 07, 2013
I recently read a fascinating change management story by Tom Fox "How to Introduce Change into Your FCPA Compliance Program (Without Blowing It Up)". In particular “work discovery” – this concept is supported very strongly from an engineering point of view as well. In mechanical engineering there’s control theory - the concept of operating a dynamic system that isn’t perfect in the face of environmental disturbances. An open loop control system tries to understand how things should work as a basis for operating. A closed loop system objectively measures the outputs of the system as a basis for operations. It turns out that closed loop control is easier and more effective. When you evaluate the actual work, the output, you will learn the discovered disconnects are an opportunity to adjust the system so that you get the result you want.  To put that in compliance terms work discovery can identify a problematic transaction and if we look for a pattern of disconnects we can find the actors – employees, agents, vendors – that need out attention.  The adjustments may be additional training, deeper diligence on a vendor, or an investigation. Whether you’re a student of Thucydides or Herodotus or control theory, managing and improving a process based on an objective observation of the actual results is a great concept.
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