At Legal Week in New York City, Chris Dale interviewed Erin Plante of Legility. Erin Plante is responsible for financial crime investigations and cross-border compliance at Legility.
I asked her about the development of investigations around the world and, in particular, the role Legility plays in conducting them.
Investigations, and the triggers for them, take place in multiple jurisdictions and people work as a team all over the world to manage this. Legility has data center in many places and can set up collection and processing systems anywhere – this is particularly helpful in areas where it is difficult to move data around either because of deficiencies in communications or because of regulatory restraints.
As a result, investigations run more smoothly and can get accurate and timely results notwithstanding local difficulties.
Investigations are generally reactive and retrospective. Legility also enables clients to be proactive in monitoring and ensuring compliance. This is becoming increasingly necessary, especially in industries which are heavily regulated and which are often investigated.
The role of technology is increasing. Regulators know what is available and expect organizations to make use of relevant technology.
Erin Plante said that it is not just the FCPA and UK Bribery Act which concern organizations. China and Brazil are among the countries which have enacted new regulations aimed at identifying and stopping corruption.
Legility can look at data, at accounting information and at emails to identify potentially corrupt situations early. As well as anticipating actual problems, this enables organizations to show regulators that they are making good-faith efforts by pointing to their policies and the monitoring programs.
The role of technology is increasing. Regulators are not necessarily the fastest adopters of technology themselves, but they know what is available and expect organizations to make use of relevant technology.
It is not enough simply to look at the main email and accounting systems. Much happens on what WeChat or Slack, and it is common to find spreadsheets kept locally and away from the main accounting systems. It is impossible to investigate these properly without the use of technology.