THE USE OF AI TO UNCOVER EVIDENCE OF CORRUPTION THAT VIOLATES THE FCPA AND THE UK BRIBERY ACT

Perhaps the most difficult evidence to expose in corruption cases are the cleverly-concealed payments made by vendors to obtain and retain business from government officials in the developing world. Those tricky, below-the-waterline bribes, which are artfully constructed by lawyers for major US and UK companies to defy conventional investigation, are extremely hard to find, because compliance officers have no idea where to look. Companies that will go to any lengths to get business from governmental officials task their attorneys with building an investigation-proof cover story, to insure that they will not be deciphered and found to be bribes and kickbacks given indirectly to get those lucrative contracts.

The maddening thing is that not only do the corrupters perpetrate those criminal acts, they often coach the recipients, senior government officials with authority over spending, on specifically how to act during and after the charade is conducted. In short, they tell the officials how deal with this illicit money, so that their actions do not unwittingly allow compliance to reach out and find the payments. This greatly reduces the chances of subsequent discovery.

That was the past; today, emerging technology affords the compliance officer a potent weapon to wield against those hidden payments, which can now be exposed, not through labor-intensive enhanced due diligence searches, but by employing programs that feature advanced artificial intelligence, which can find those elusive payments, even if they appear to be legitimate transactions totally unconnected to the matters under investigation. This means that what was out of reach before, now shows up in your search, because the platform you selected has a capability far beyond that of your old legacy toolbox. AI is going to show you where that dirty money went, how it was manipulated to conceal it from view, and who received it; count on it to succeed.