The FCPA Report interviewed Manatt's Jacqueline Wolff, co-chair of the firm's Corporate Investigations and White Collar Defense practice, for the final article in a series discussing third-party auditing to mitigate anti-corruption risks.
The FCPA Report says significant corruption risks continue to stem from the actions of third parties that companies hire. When auditing a third party, the auditors should review relevant transactions. Transactions that would typically be tested at random include time and expense entries, commission expenses, payments from the third party's accounts, and others.
Wolff told the publication that the auditors should ensure there is proper backup for all expenditures. She said, "If money is going out the door, where is the backup to describe what the money was being used for? Why did it go out? Who approved the money going out? Is there an approval process before money goes out? For example, if the company covers expenses, is there backup from each vendor for each expense? Is there a due diligence process if there needs to be?"