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FORENSIC & INTEGRITY SERVICES



Our forensic consultants provide you with the benefit of our broad sector
experience, deep subject-matter knowledge and the latest insights from our work
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Successful organizations depend on their reputation for keeping promises,
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Embracing integrity means doing what you say you will do, with unerring
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harness their skills to grow your business. A foundation built on integrity is
critical because today’s talent values purpose-driven organizations. It can also
help you develop stronger partnerships with suppliers and work more effectively
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Our team works to give you the benefit of our broad sector experience, our deep
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AMERICAN RESCUE PLAN ACT RESOURCES FOR STATE AND LOCAL GOVERNMENTS

Learn how to use your ARPA funds to have a transformative impact for the long
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We can provide people, process and technology to support states in fulfilling
obligations to DoB and comply with federal guidance.

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Our dedicated global team of investigators, forensic accountants, compliance and
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commercial and financial matters in legal proceedings, to managing claims to
recover financial losses, EY teams provide robust knowledge from an independent
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Forensic Data Analytics (FDA) is a critical element of nearly every way in which
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The Transaction Forensics team assists organizations and legal counsel in
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Effective third-party risk management
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OUR LATEST THINKING ON FORENSIC & INTEGRITY SERVICES

BUILDING CONFIDENCE IN YOUR ORGANIZATION’S SECTION 889 PART B COMPLIANCE PROGRAM

The application of the Part B legislation means that entities have to consider
the entire enterprise in eliminating Section 889 exp…

16 Feb 2022 Sajeev Malaveetil

INDEPENDENT OVERSIGHT OF CAPITAL PROJECTS THROUGH INTEGRITY MONITORING

Part 2 of 3 in a series that focuses on how to mitigate business risks

11 Feb 2022 Brian Browne

HOW DUE DILIGENCE REDUCES THE REGULATORY RISK FOR SPAC TRANSACTIONS

Now is the time to reassess due diligence procedures and consider supplementing
the process to address the increased re…

3 Feb 2022 Amanda Massucci

COST SIMPLIFICATION AND RESTRUCTURING FOR COMPETITIVE ADVANTAGE

Manufacturers and service contractors alike are turning to restructuring
solutions to meet the needs of the evolving market.

2 Feb 2022 Sajeev Malaveetil

CMMC 2.0 UPDATE

On November 4, 2021, the Department of Defense (DoD) announced long-anticipated
changes to the Cybersecurity Matu…

12 Jan 2022 Sajeev Malaveetil

DOJ CIVIL CYBER-FRAUD INITIATIVE

The goal is to combine the department’s expertise in civil fraud enforcement,
government procurement and cybersecurity to c…

21 Dec 2021 Courtney Black

HOW TO REDUCE AND MITIGATE FRAUD IN CONSTRUCTION AND REAL ESTATE

Part 1 of 3 in a series that focuses on how to mitigate your risk through
prescreening of third-party vendors and contractors.

17 Dec 2021 Brian Browne

COVID-19: ESTABLISHING COST REASONABLENESS FOR FEMA

Part 4 of 6 in a series that focuses on lessons learned and leading practices in
COVID-19 disaster cost recovery.

11 Nov 2021 Allen Melton

HOW TO ENSURE COMPLIANCE AND CONTROL IN CRYPTOCURRENCY

As cryptocurrency and blockchain technology continue to become more integrated,
regulations and regulatory scrutiny continue to progress.

3 Nov 2021 Walid Raad

THE BUILDING RESILIENT INFRASTRUCTURE AND COMMUNITIES (BRIC) PROGRAM

FEMA’s Pre-Disaster Mitigation (PDM) grant program has been replaced with the
new Building Resilient Infrastructure and Communities (BRIC).

1 Oct 2021 Allen Melton

IMPACT OF CYBERSECURITY EXECUTIVE ORDER ON US GOVERNMENT CONTRACTORS

Evolving cyber regulations under Biden’s executive order mean organizations must
adjust to keep US government contracts.

20 Sep 2021 Sajeev Malaveetil

HOW DOMESTIC SOURCING POLICY IN US FEDERAL CONTRACTING HAS EVOLVED

Several executive orders and regulations have accelerated the focus on domestic
sourcing, particularly the Buy American Act.

7 Sep 2021 Sajeev Malaveetil
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EY FORENSICS WEBCASTS

FALSE CLAIMS ACT – GOVERNMENT PROCUREMENT AND CONTRACTING

In this webcast, panelists will share insights on the latest trends related to
FCA enforcement, DOJ priorities and managing FCA risk.

26 Jan 2022 07:00 your local time

FCA ENFORCEMENT IN HEALTH CARE AND LIFE SCIENCES

In this webcast, panelists will cover trends and outlooks on anticipated FCA
enforcement in the health and life sciences industry, including risks related to
the CARES Act and FEMA funding.

25 Jan 2022 07:00 your local time

REGULATOR UPDATE — SPECIAL PURPOSE ACQUISITION COMPANIES (SPACS)

Understanding and proactively managing emerging compliance risks.

21 Jun 2021 18:00 your local time

US HEALTH SECTOR POLICY AND COMPLIANCE UPDATE

In this webcast, we’ll present health and tax policy updates and compliance
matters for entities operating within the US health sector.

17 Jun 2021 18:00 your local time

CARES ACT PROVIDER RELIEF FUND REPORTING AND ENFORCEMENT

Be prepared.

10 Jun 2021 18:00 your local time

HOW A ROBUST COMPLIANCE PROGRAM CAN HELP ORGANIZATIONS DRIVE ESG COMMITMENTS

Environmental, social and governance – compliance considerations for 2021 and
beyond.

6 Apr 2021 18:00 your local time

2021 — A FOCUS ON FINANCIAL FRAUD DURING COVID 19

In this webcast, we’ll discuss risks, issues and focus areas of the DOJ and SEC
from a regulatory perspective and fraud scenarios that have come to light as a
result of the pandemic.

9 Feb 2021 19:00 your local time

HOW TO NAVIGATE THE FINANCIAL STORM IN ATHLETICS AND HIGHER EDUCATION

In this webcast, EY and Barnes & Thornburg LLP will discuss the current crises
facing higher education institutions and athletic departments.

29 Sep 2020 18:00 your local time

WHAT US GOVERNMENT CONTRACTORS CAN EXPECT NEXT

In this webcast, panelists discuss CARES Act enforcement and oversight and
federal contract audit trends.

17 Sep 2020 18:00 your local time

WHAT GOVERNMENT CONTRACTORS CAN DO TO HELP IN COST RECOVERY

In this webcast, panelists discuss CARES Act section 3610 and requests for
equitable adjustments (REAs) in relation to recovering costs.

11 Jun 2020 19:00 your local time

COVID-19: HOW STATE AND LOCAL GOVERNMENTS CAN RECOVER COSTS

In this webcast, panelists discuss the different steps that will help state and
local governments recover costs during the pandemic.

16 Apr 2020 18:00 your local time

US CORONAVIRUS AID, RELIEF AND ECONOMIC SECURITY (CARES) ACT: WHAT YOU NEED TO
KNOW

In this webcast, learn about US government actions to support recovery and
econimc relief in response to the COVID-19 pandemic.

30 Mar 2020 17:00 your local time
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Case Study
The better the question The better the answer The better the world works
Case Study


HOW TEVA PHARMACEUTICAL IS MANAGING THIRD-PARTY RISK BETTER

THE COMPANY IS USING DATA ANALYTICS AND WORKFLOW DESIGN TO RE-ENGINEER
COMPLIANCE AS A DRIVING FORCE FOR BETTER DECISION-MAKING AND CHANGE.

Case Study
The better the question The better the answer The better the world works
Case Study


HOW DO YOU BUILD TRUST AS YOU SCALE AND CONFORM?

EFFECTIVELY MEETING LEGAL REQUIREMENTS WAS CRUCIAL — BUT THAT WAS JUST THE
STARTING POINT FOR TEVA.

Managing the risks of corruption arising from third parties is one of the most
difficult challenges facing global organizations. Enforcement of the US Foreign
Corrupt Practices Act (FCPA) has increased significantly in recent years, with
companies paying a record US$2.9 billion to resolve cases in 2019, according to
the FCPA Blog. The FCPA Clearinghouse shows third-party intermediaries have been
involved in 89% of enforcement actions. Worldwide, anti-corruption efforts have
intensified, with increased cooperation among different jurisdictions.

Teva Pharmaceutical Industries, headquartered in Israel, is a global leader in
generic and specialty medicine. In 2016, it agreed to a settlement with US
authorities over FCPA violations. Teva agreed to enhance its compliance program
and improve due diligence for third parties while reporting to an independent
compliance monitor for three years. And if that wasn’t a big enough challenge,
the pharmaceutical giant underwent a corporate restructuring program designed to
cut US$3 billion in costs.

Compliance

02000000

Teva was processing up to 2,000 requests to use third parties every year.

Lori Queisser, who became Teva’s Global Chief Compliance Officer in 2015, knew
meeting legal requirements would just be a starting point. The company’s lengthy
compliance processes were hurting productivity, without necessarily reducing
third-party risk. Teva’s official goal became to “build the best and most
respected global compliance program in the industry — a program that works in
partnership with the business to prevent issues.”

Queisser discovered that a spate of corporate acquisitions had saddled Teva with
a dozen legacy systems, each with its own finance and procurement processes,
some of them manual. Getting approval to engage a third-party representative
could take weeks or even months. Teva, which has roughly half a million vendors
and customers, was processing up to 2,000 requests to use third parties every
year.

“We were spending millions and millions of dollars on third-party due diligence,
as does every US-listed public company, but we weren’t reducing our risk,”
Queisser says. 

Case Study
The better the question The better the answer The better the world works
Case Study


THE GOAL: ENHANCE VENDOR COMPLIANCE WHILE SPEEDING BUSINESS DECISIONS

THE EY APPROACH IS DATA DRIVEN WITH THE HELP OF INNOVATIVE WORKFLOW DESIGN AND
ANALYTICS TECHNOLOGIES.

Queisser was looking for a “game-changer, to make a disruptive move in this
space.” Teva therefore engaged EY Forensic & Integrity Services to develop a due
diligence system designed to be proactive rather than reactive, using advanced
analytics and technology. EY professionals built a database using both
proprietary data and public records such as regulatory filings, court rulings,
sanction lists and news reports. Assembling the right data was critical to
gaining the insights needed to vet third parties. It also laid the groundwork to
apply advanced analytics and artificial intelligence (AI) to evaluate risks even
more effectively.

Teva and EY professionals developed business rules that helped enable algorithms
to calculate a risk score for each potential business relationship.  The
pre-screening tool allows vendors with a low-risk ranking to be engaged
immediately (subject to an executed contract), while higher-risk parties face
more probing, such as a questionnaire, investigation or deliberation by a
due-diligence committee. In a 30-day pilot, the system evaluated risk for twice
as many third parties as Teva had previously assessed over an eight-month
period.

At the same time when Teva began integrating the pre-screening tool into its
business processes, the company was using dozens of purchase-to-payment (P2P)
processes, often implemented differently across 60 countries. Teva needed to
make sure its procurement policies were followed consistently as related to the
engagement of third parties. The EY teams collaborated with Teva to design an
innovative, transparent workflow that walks business users through the control
process, routes relevant information to the right people, and creates an audit
trail. The system automates the process based on business rules applied to key
decision points, with disparate P2P systems feeding data into the pre-screening
tool.

Risk

030000m

RiskMate provides pre-secreening for more than 300 M entities.

Change management was a huge challenge. Teva’s business owners are accountable
for compliance but they had to be convinced that the changes needed to
effectively implement a new system were worth making. It wasn’t just a matter of
gaining buy-in among a few leaders — nearly 40% of Teva’s 43,000 employees were
scheduled for training by the end of 2019.

Using the new pre-screening tool for Teva’s reconciliation efforts went a long
way to gain the trust of business stakeholders. Compliance professionals, along
with the finance and procurement teams, had to identify all customers and
vendors worldwide to determine if they met the definition of a third-party
representative and to perform proper due diligence if it hadn’t already been
done. The first phase, which was done manually, took more than a year to cover
ten countries. But the second phase, which used the pre-screening tool to
automatically assign risk levels, took less than five months to reconcile
vendors and customers in 26 countries.

“That really helped us to gain the trust of management and the trust of the
business sponsors that would be using the tool on a daily basis,” says Tali Guy,
Vice President of Compliance and Third-Party Due Diligence.  

Implementing a new workflow along with data analytics has sped up all aspects of
the due diligence process, from data collection, cleansing and analysis to
risk-ranking and evaluation.  The pre-screening tool contains roughly 25 million
records in more than 45 service categories. The system can also tap into other
proprietary databases, providing pre-screening for more than 300 million
entities. A case management tool manages tasks from a central dashboard,
enhanced by interactive visualizations and audit trails to give leaders the
information they need to make informed and timely decisions.

Case Study
The better the question The better the answer The better the world works
Case Study


DELIVERING TIMELY RESULTS FOR BUSINESS OWNERS

THE NEW APPROACH PROVIDES RESOURCE EFFICIENCY WHILE OFFERING QUICKER RESPONSE,
INCREASED VISIBILITY AND CONSISTENCY AT THE SAME TIME.

The time needed to gain approval for engaging third parties has dropped from
weeks or months to as little as just a few hours. This allows the compliance
team to focus on examining higher risks. In 2020, about 75% of Teva’s
third-party representatives will be pre-screened through the new tool.

Previously, business stakeholders received no information on a request to engage
a third party until it was approved or denied. Now, they can go into the system
and see the status of every request. The system automatically reminds third
parties and business sponsors to complete questionnaires and denies requests if
a timely response isn’t made. 

> We are leaning into compliance rather than looking in the rearview mirror.

Lori Queisser
Teva Pharmaceutical Global Chief Compliance Officer


HOW EY CAN HELP

INTEGRITY AND COMPLIANCE

As regulatory enforcement and public intolerance of corporate misconduct
increase, EY professionals help you strengthen your integrity and compliance
frameworks. And, should violations occur or allegations of fraud or corruption
arise, the teams help you respond quickly to safeguard your business.

Read more

Dashboards help enable users to view all third parties and their risk levels.
Another benefit of the pre-screening tool is Teva now has a vetted database of
vendors and customers. This data- and analytics-driven approach has helped Teva
shorten the time required to onboard third parties, drive consistency everywhere
it does business, and reduce the cost of third-party due diligence.

Teva’s compliance leaders expect their data- and analytics-driven approach to
reducing risk will continually become more proactive, while providing valuable
insights that help in business planning and decision-making. Teva is exploring
the use of advanced AI technologies to enhance pre-screening of third parties.
Machine-learning algorithms can be trained on reviews, investigations, approvals
and denials to create a predictive model that identifies risk indicators for
potential new relationships.

While these advanced technologies are still in their early stages, they could
eventually suggest new innovations for evaluating third parties. In addition,
this system can easily be adapted for other compliance programs such as
detecting counterfeit drugs or adhering to privacy regulations.

“We are leaning into compliance rather than looking in the rearview mirror,”
Queisser says.

The primary goal of Teva’s compliance function is to provide business owners
with the right tools, resources, policies and training to help them make better
decisions. This new approach not only manages risk more efficiently — it also
positions the compliance function as a driving force for change within the
company and as a model for the entire industry.

This case study was first published by MIT Sloan Management Review Connections.


 * SHOW ARTICLE REFERENCES
   
    1. Foreign Corrupt Practices Act Clearinghouse,” Stanford Law School,
       accessed June 10, 2020, http://fcpa.stanford.edu.




HOW CAN WE HELP?


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