Lextegrity’s software is the leading compliance solution in the market related to managing risks related to fraud, corruption, sanctions, kickbacks, and conflicts of interest. Our software has been before enforcement agencies globally in 12 separate company engagements and was even cited by the SEC as a remediation factor in a client’s FCPA resolution. It has been chosen after the appointment of compliance monitors or after the start of an investigation and has been a factor in resolving those matters, including helping to secure a DOJ declination.
Lextegrity’s software has assisted global companies in connection with enforcement agency actions in the United States, Brazil, Canada, France, Sweden, Switzerland and South Africa, as well as by the World Bank.
The June 2020 update to the U.S. Department of Justice (DOJ) Evaluation of Corporate Compliance Programs guidance (2020 Guidance), emphasized that companies need to anticipate and proactively identify risk by having access to, and using, data. The 2020 Guidance emphasized that corporate compliance programs must utilize actionable risk insights on an ongoing basis and specifically notes that companies should focus their resources on high-risk transactions.
“Prosecutors may credit the quality and effectiveness of a risk-based compliance program that devotes appropriate attention and resources to high-risk transactions, even if it fails to prevent an infraction.”
U.S. Department of Justice, Criminal Division, Evaluation of Corporate Compliance Programs (Updated June 2020).
Since 2020, the DOJ has heightened its expectations to include immediate detection of non-compliance. In May 2022, Assistant Attorney General Kenneth Polite, a former in-house Chief Compliance Officer himself, stated:
“I want to know whether you are doing everything you can to ensure that when an individual employee is facing that singular ethical challenge, he has been informed, he has been trained, and he has been empowered to choose right over wrong. Or, if he makes the wrong choice, you have a system that immediately detects, remediates, disciplines, and then adapts to ensure that no others follow suit (emphasis added).”
Assistant Attorney General Kenneth Polite
Lextegrity’s Compliance Monitoring product is the leading out-of-the-box compliance monitoring solution that meets the DOJ expectations in regard to immediate detection and continuous monitoring of transactions. Lextegrity’s Approvals & Disclosures and Third-Party Management products are the leading highly-configurable compliance workflow automation solutions to help manage front-end compliance risks before a transaction even occurs.
Helping a global US-based pharmaceutical company secure a declination from the DOJ and a modest SEC fine, in which the SEC cited Lextegrity’s software specifically as a significant remediation factor
Being selected by a global Brazil-based manufacturing company in the last year of its monitorship and helping to resolve the monitorship on a timely basis
Being selected by a global European-based life sciences company in the last year of its monitorship and helping to gain certification from the Monitor
Helping a global Brazil-based manufacturing company during its post-deferred prosecution agreement self-reporting period
Helping a global European-based technology company resolve a multi-jurisdictional investigation
Helping a global European-based technology company during an ongoing monitorship
Helping a global US-based pharmaceuticals company during an ongoing anti-kickback investigation
Helping a global US-based energy company post settlement to minimize the risk of recidivism
Helping a global US-based life sciences company post settlement to minimize the risk of recidivism
Helping a global Japan-based life sciences company post settlement to minimize the risk of recidivism
Helping a global Canada-based engineering company enhance its controls during its monitorship
Helping a global France-based technology company in connection with an ongoing government investigation
“I would have viewed Lextegrity’s approach of managing risk across the life-cycle of spend – from the due diligence process through the spend process itself – very favorably. A technology and approach that tests the entirety of your financial transactions using multiple risk analyses simultaneously provides a much higher degree of comfort around whether your program is actually operating effectively than doing due diligence only or relying only on infrequent sample based auditing to supplement your diligence. In fact, a handful of companies have implemented exactly this approach and shown it to the DOJ over the years and prosecutors know first-hand what is now possible and will continue to expect organizations to up their game and implement solutions like that.”
Hui Chen
Former DOJ Compliance Counsel Expert
"Ultimately, the enhancements to our compliance program from the implementation of Lextegrity's product enabled Fresenius Medical Care to satisfy our obligations under our agreements with the DOJ and SEC. Lextegrity interfaced expertly with dozens of people within the company as well as our outside counsel and the Monitor team, to help us achieve our aims with respect to our program enhancements and our monitorship. But most importantly, we now have a long-term scaled solution driven by technology to support effective monitoring of Fresenius Medical Care’s transactions going forward."
Patrick Murphy
Global Head - Litigation and Investigations
“Lextegrity has built the future of compliance. Its software allowed us to enhance compliance controls globally and bring significant innovation to our compliance function. Our compliance transformation depended on technology, and we had the best possible technology partner supporting us . . . Its integrated data analytics, monitoring and spend pre-approval software allowed Alexion to enhance compliance controls globally and bring significant innovation to our compliance function.”
Piyush Sharma
Former Chief Compliance Officer
"Lextegrity's team of expert, former in-house counsel and auditors understand what we're doing and bring the substantive knowledge necessary to deploy an effective and efficient tool that works for Compliance and the business."
Mauricio Almar
Assistant General Counsel
To meet their obligations and satisfy the Monitor, Fresenius Medical Care selected the Lextegrity Integrity Gateway Compliance Monitoring software to enable monitoring and remediation of compliance risk in global vendor spend and distributor/reseller transactions.
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Lextegrity interviewed Hui Chen, the first-ever Compliance Counsel Expert at the U.S. Department of Justice (2015-2017), to discuss DOJ expectations, evaluation processes, and real-life examples where data analytics could have saved companies time and money, as well as address common concerns compliance programs have when approaching data analytics.
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In this discussion with the former Chief Compliance Officer at Alexion, learn how they are using Lextegrity’s Compliance Monitoring solution and how their approach to data analytics and continuous monitoring can inform your digital compliance journey.
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Lextegrity's software is a proven solution and has been cited by the SEC. The Alexion SEC FCPA order (see paragraph 35) cites Lextegrity's third-party spend monitoring software as a key item in the company's remediation efforts.
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