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The Evolving Role of Technology Compliance Analytics Program Sam Pailca Associate General Counsel Office of Legal Compliance | Investigations May 9, 2019

The Evolving Role of Technology - Enforcement Forum · 2019. 5. 8.  · Moneymart PAT Public Sector Commercial 80 40! Risk Score Geo Partner Customer Discount and Dollar Daily HRP

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Page 1: The Evolving Role of Technology - Enforcement Forum · 2019. 5. 8.  · Moneymart PAT Public Sector Commercial 80 40! Risk Score Geo Partner Customer Discount and Dollar Daily HRP

The Evolving Role of TechnologyCompliance Analytics Program

Sam PailcaAssociate General CounselOffice of Legal Compliance | InvestigationsMay 9, 2019

Page 2: The Evolving Role of Technology - Enforcement Forum · 2019. 5. 8.  · Moneymart PAT Public Sector Commercial 80 40! Risk Score Geo Partner Customer Discount and Dollar Daily HRP

“We have questions about a contract you entered into with…”

“We need help getting this deal across the goal line…”

“We’re interested in learning more about your relationship with channel partner X…”

Page 3: The Evolving Role of Technology - Enforcement Forum · 2019. 5. 8.  · Moneymart PAT Public Sector Commercial 80 40! Risk Score Geo Partner Customer Discount and Dollar Daily HRP

Use digital technologies to create an early warning and monitoring system for compliance risks.

Page 4: The Evolving Role of Technology - Enforcement Forum · 2019. 5. 8.  · Moneymart PAT Public Sector Commercial 80 40! Risk Score Geo Partner Customer Discount and Dollar Daily HRP

Microsoft’s Compliance Analytics Program

1Implement programs that provide prioritized, risk-based analytics.

2Deliver reliable data integrated into aligned business processes.

3Move beyond “reporting” to “identifying & predicting” compliance risks.

Data → Insight → Action

Using digital technology and algorithms, identify “high risk” dealsthat require additional compliance oversight before we enter into a sales contract.

Location

India.

Partner

X com

Sector

Commercial

Risk Score

5

China

Iceland

Robert Finn

Jason Hunt

Public Sector

Commercial

90

20

!

!Hungary

Brazil

Moneymart

PAT

Public Sector

Commercial

80

40

!

Risk Score GeoPartnerCustomer Discount and Dollar

Daily HRP Insights

Anomalies detected CollusiondetectedCriminal

Activity detected

Identify “high risk” channel partners (e.g., resellers and distributors) for deeper reviews and enhancedcontrols to mitigate risks.

Page 5: The Evolving Role of Technology - Enforcement Forum · 2019. 5. 8.  · Moneymart PAT Public Sector Commercial 80 40! Risk Score Geo Partner Customer Discount and Dollar Daily HRP

Sales team or reseller creates a sales quote

QUOTE DEAL

Run algorithm against quote to identify riskiest deals based on data attributes in real-time

Location

India.

Partner

X com

Sector

Commercial

Risk Score

5

China

Iceland

Robert Finn

Jason Hunt

Public Sector

Commercial

90

20

!

!Hungary

Brazil

Moneymart

PAT

Public Sector

Commercial

80

40

!

Risk Score GeoPartnerCustomer Discount and Dollar

Analytics monitor risks and deal is approved if controls are satisfied

Bank ReconciliationSECURE BANK Jane

Customer

Debit Card 30.00

13.00 Credit JohnSmith

Debit Card

Paycheck

PaymentTransaction type

Payor Transaction type

XYZ Corp

Review identified deals and conduct control checks and mitigate risks with stakeholders

821

0 100

RISK-SCORE DEAL

Risky attributes detected:• Sales Geo• Reseller• Customer Vertical• Deal Revenue• Deal Discount

Page 6: The Evolving Role of Technology - Enforcement Forum · 2019. 5. 8.  · Moneymart PAT Public Sector Commercial 80 40! Risk Score Geo Partner Customer Discount and Dollar Daily HRP

Provide real-time insights to make more informed compliance and business decisions at different points of partner lifecycle

High Tech Risk Insights

Segments

Partner Makeup

Next Best Action External Reports

Key Risks Risk Details

As partners are being on-boarded, algorithm identifies the riskiest partners for additional vetting

Renner Group

RISK SCOREFraudulent behavior

detectedClick here to stop

application8210100

Vetting Dashboard

85%

High Tech

Partner vetting is enhanced by leveraging algorithm insights and data for targeted reviews and checks

1

Daily HRP Insights

Anomalies detected

CollusiondetectedCriminal

Activity detected

Perform deeper review and implement controls to mitigate risks for partners identified as “High Risk”

HRP Report

Onboarding Dashboard