It’s a little known secret, but FCPA whistleblowers can obtain financial rewards of 10% to 30% of recovered sanctions.
Considering the 2.09 billion USD fine for Airbus, whistleblowers can be more than motivated.
When the SEC comes to control your company’s supplier database, what treasures might they find lurking in there? Do you have any “consulting” companies that you are paying large sums to, without any real services delivered? Who set up those companies?
Do you have any special employees that are receiving very large commissions, that are not within the normal rates for commissions?
Do you have shell companies, that send you consecutively numbered invoices?
SAP supplier database typically holds over 40K suppliers in them. So it can be difficult to get an overview of all the risky ones.
Automated regular screening of your third parties can ensure you have a clear idea of where the risks are before the SEC comes to do its checking.
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