Overview
A monitor is appointed as part of a Deferred Prosecution Agreement (DPA) to ensure institutions make good on promises made as part of remediation. Non-compliance could result in prosecution and/or additional financial penalties. The monitor identified a control gap where (in certain circumstances) payments could be made to vendors before Anti-Bribery & Corruption checks were performed. An urgent resolution was required, as the current process would inevitably have meant putting a hold, or severe delays to, onboarding of new vendors and making of vendor payments.
Identifying roles and responsibilities helped resolve monitor findings.
Challenges
The vendor onboarding and payment process spanned four different groups (Procurement, Third Party Risk Management, Accounts Payable and Ethics), with ownership and roles & responsibilities unclear in certain circumstances and sub-optimal communication between groups. The affected processes also did not have an end-to-end owner, making the finding of consensus and arbitration of solution options a challenge. Alacer overcame these challenges by running a workshop with all relevant stakeholders to present, discuss, agree and implement the best solution.
Results
Within the designated timeframe, Alacer consultants resolved the monitor finding with a tactical process change as well as a strategic solution thereby facilitating the continued and uninterrupted vendor onboarding and payment processes. Additional deliverables including process maps and procedure documents were also used for training purposes, and to develop compliance testing scripts.
