KPMG united disparate reporting and compliance silos in a single, transparent system.

KPMG viewed the engagement in three defined phases: solving the immediate problem in one country; examining 150 additional businesses to determine what compliance risks, if any, existed; and remediating any identified issues.  

1. Initiation phase

Hit the ground running

KPMG Forensic examined the company’s entities where the problem had occurred and found that the company’s compliance standards were inconsistent and outdated. With the goal of establishing a system that would ensure compliance throughout the network, KPMG began developing a framework that could be rolled out across the company. It had to be strong enough to manage risks in the over 100 countries where the company operated and flexible enough to give the individual entities the ability to do business legally and in line with local customs.

The KPMG framework addressed all compliance activities from an anti-bribery, anti-corruption (ABAC) perspective. Both broad and detailed, it covered policies and procedures, processes, controls, document retention, segregation of duties, and other areas subject to ABAC risk. KPMG enumerated the policies required to manage third-party risks and recommended the reduction of ABAC risk exposure through tighter controls, employee training, transaction document retention, technology enablement, and similar compliance measures.

3. Remediation phase

Enhancing the system

While KPMG had already built a framework for compliance and completed a risk analysis of more than 150 entities in five countries, the cultural aspects were more complicated. The client’s region-driven philosophy allowed each entity to operate in the way that suited it best. This approach had certain business advantages, but it was a compliance challenge. Without centralized oversight and a clear set of rules, there were layers of legal and accounting conflicts that could inflict painful bites on a global company.

Each entity, however, enjoyed its autonomy and was reluctant to change. KPMG worked to educate the client and its network on the necessity of a more centralized, compliance-focused culture in today’s international business world. Without a more robust data collection and analysis capability, the enterprise would always be at risk of incurring violations. Without defined standards, practices that were legal in some jurisdictions could cause problems in others. The challenge was to get all leaders to deliver a globally consistent, company-wide message while giving each the flexibility to adapt to local conditions.

To implement the program successfully, KPMG both respected the cultural sensitivity and requirements of each given country and crafted a consistent message that transcended borders. Key to the effort was committed leadership, first from headquarters and then from local offices. Once leaders understood that the benefits of a compliance-focused culture more than offset the inconveniences of revamping their systems, and once they understood that the cost of noncompliance could be several times greater than the cost of upgraded technology, they were eager to adopt the recommendations.

The three-year project took place mostly during the pandemic, and the successful outcome was due in large part to the work of local KPMG teams. With travel nearly impossible, they were responsible for in-country work, while KPMG Forensic provided supervision and oversight from the US. The project exemplified the close teamwork and shared skills that bind together the KPMG global organization.