Situation: Verify and act upon whistleblower allegations within a sea of global enterprise data
Compliance officers at large multinational corporations are facing increasing regulatory scrutiny and data volumes. When they sense trouble, it is critical to find out the extent quickly. While there is no one-size-fits-all solution to SEC, FCPA, or DOJ investigations, there are technologies and workflows that prove themselves over and over again to be adaptable, reliable, and quickly deployable.
FTI Technology recently concluded one investigation for a multinational company seeking to learn more about the allegations made by a whistleblower. The whistleblower’s claims were profound but narrow; the client wanted to know if the whistleblower’s claims were accurate and if there were more troubles that the whistleblower didn’t bring to their attention. Furthermore, the client needed to know if the whistleblower’s claims were true in several different parts of the world. The project spanned millions of documents in multiple languages, requiring multilingual attorneys and investigators skilled in applying analytics technology to accelerate workflows.
FTI Technology deployed two concurrent workflows – one with a team of attorneys, and another with a team of experienced investigators. One workflow was reliant on Continuous Active Learning (“CAL”), a technology in which the software continually refines its results based upon iterative feedback from reviewers. With CAL, FTI’s attorneys were able to find documents that were most similar to other interesting documents. The attorneys would spend the day reading and categorizing documents of interest to the client, while the CAL technology would spend the evening combing the entire data set for other documents that the attorneys wanted to read next.
While the attorneys used CAL, FTI’s investigators used FTI Technology’s Find Facts Fast (“FFF”) workflow. FFF uses analytics technologies to compare document populations without requiring the investigator to read the document population. For this project, FTI’s investigators were able to use the Ringtail platform and find similarities between the allegations in the whistleblower letter and activities that originally seemed quite benign. Flagging these similarities for attorneys led to insights that helped the client take action quickly.
FTI Technology’s "researchers" – a term that spans both the attorneys and investigators using CAL and FFF technologies and workflows – have years of experience on investigations from all over the world. FTI’s researchers are familiar with the use of predictive coding technologies to reduce the time and money that goes into urgent investigations. Similarly, FTI’s researchers are familiar with the workflows that are constructed to handle rapidly evolving understanding from each investigation.
Impact: The client understood and could act upon the facts of the matter a month ahead of schedule, and at 50% of the cost of a regular investigation
These projects would be much easier if there was some panacea that researchers could apply in every case. Unfortunately, client challenges are often unique and require a bespoke approach. To help address this, FTI Technology has a wide variety of software applications to solve those problems without compromise. In the whistleblower case, the FTI Technology client expected to spend a great deal of money on a very large group of contract attorneys to read every single document. After spending time learning the details, FTI Technology proposed a different approach that eventually cost 50% less than the initial budget. In addition, FTI Technology helped the client understand the facts of the matter more than a month ahead of schedule, enabling them to proactively take action rather than reacting to externalities.
When dealing with fast moving investigations, such as SEC, FCPA, or DOJ investigations, it is important that the compliance officer is equipped with the right facts to move forward. FTI Technology provides the right technology, people and processes to help clients find those facts fast.