A US group with an education-sector venture in India already knew its anti-corruption controls were thin, and needed them built. The instruction was to build the program: the documents, the mechanics, and the rollout.
“A control matrix mapped each risk to the control that answered it.”
The work, carried out during my tenure at a global investigations firm, produced the working parts of an anti-corruption compliance program. Risks were scored against the business's actual exposure: where it met government, where it paid intermediaries, where discretion sat. A control matrix mapped each risk to the control that answered it. Policies were drafted to be followed in practice, a training packet built for the people who would carry the rules, and a rollout workplan sequenced so the program could be brought into use step by step.
Program design is the constructive side of anti-corruption work, and it informs the investigative side. Having built control matrices, I read a client’s transactions knowing which control should have caught a problem, and what its absence suggests.