ACI Insights - Building a Data-Driven Anticorruption Compliance Program

Building a Data-Driven Anticorruption Compliance Program

Building a Data-Driven Anticorruption Compliance Program

March 1, 2023

By Jaclyn Jaeger

For more than two years now, heads of the U.S. Department of Justice have maintained a steady drumbeat that they expect companies today to have in place a sound data analytics compliance program to proactively mitigate risks.

An especially significant development portending the DoJ’s intensified focus on data-driven compliance programs was the onboarding in September 2022 of Matt Galvin into the Fraud Section’s recently restructured Corporate Enforcement, Compliance and Policy (CECP) Unit.

As former head of compliance at global brewing company Anheuser-Busch InBev (AB InBev), Galvin is a well-known compliance expert for his innovative use of artificial intelligence and machine-learning in proactively mitigating compliance risk. In 2017, Galvin spearheaded the launch of AB InBev’s advanced data analytics platform, BrewRIGHT, which culls troves of compliance and transactional data from numerous accounting and compliance systems across the company where it is harmonized into a centralized repository.

The platform runs algorithms to organize and analyze the data under such buckets as anticorruption and fraud risk, vendor management, anti-money laundering, economic sanctions, conflicts of interest, and even free beer giveaways. Specially built dashboards enable AB InBev’s compliance teams to proactively identify and monitor any algorithms flagged as highrisk and root out risks across the more than 50 markets where AB InBev operates. Simply put, the hiring of Galvin as a data analytics advisor for the Fraud Section is a strategic move.

Another significant hire at the DoJ was the appointment of Glenn Leon as the Fraud Section’s new chief, who joined the agency after serving most recently as chief ethics and compliance officer at Hewlett Packard. The onboarding of more compliance professionals means prosecutors are more adept than ever at assessing companies’ compliance programs.

“We are using every tool at our disposal to combat corporate crime, including more sophisticated data analytics and other means to proactively identify criminal conduct,” Assistant Attorney General Kenneth Polite said in Jan. 17 remarks at Georgetown University.