Compliance Programs & Risk Assessments

CRA works with clients on anti-corruption controls to institute leading practices in accordance with US and UK requirements under the FCPA and the UK Bribery Act. CRA conducts risk assessments to understand a company’s ABAC program and works with management to understand the organization’s strategic objectives and risk tolerance. We evaluate existing fraud controls and design anti-bribery and corruption protocols with a prioritized roadmap of recommendations. We also offer periodic external performance assessments to identify new risks and detect any gaps or overrides that would impact the effectiveness of key controls.

CRA specializes in sanctions and anti-money laundering compliance, encompassing enhanced Know Your Customer due diligence and sanctions risk assessments. Our team provides strategic advice on emerging market risk and effective strategies for assessing high-risk clients and implement compliance frameworks that fit the footprint and strategic risk profile of the organization. We conduct assessments of existing governance protocols and controls, evaluate transaction monitoring procedures, regulatory reporting processes, and SARs filing systems, and undertake remediation projects and conduct AML lookbacks.

CRA collaborates with management to revise, develop and implement compliance training modules that reflect newly created best practice protocols and controls. We develop include training modules and provide consultation on metrics to monitor and track employee completion of required compliance and ethics training courses.

Whether in response to regulatory inquiries or proactively monitoring for non-compliance, CRA’s data analytics experts review and combine structured data with traditional investigative methodologies to flag potentially violative transactions and problematic third parties. We aggregate and harmonize data from disparate systems to identify, prioritize, investigate, and remediate compliance risks.

The False Claims Act continues to be one of the government’s preferred tools to combat fraud, waste, and abuse, and is used to recover billions of dollars each year.  CRA is experienced at independently investigating and assessing these allegations and helping companies respond to this growing legal and compliance risk. Our team of professionals includes CPAs, CFEs, CFFs, former big four auditors and audit partners, PhD economists, former members of law enforcement, and specialists with deep industry expertise.

Healthcare providers and life sciences organizations turn to CRA to help independently assess allegations of non-compliance with the Stark and anti-kickback laws. These laws prohibit the knowing and willful payment of “remuneration” to induce or reward patient referrals or the generation of business involving any item or service payable by Federal payers, including Medicaid. These laws also prohibit physicians from referring patients to receive “designated health services” (reimbursed by Federal payers) from entities with which the physician or an immediate family member has a financial relationship, unless an exception applies. Our cross-trained team combines deep clinical, coding, billing, and operations knowledge with expertise in valuation, finance, economics, and accounting to deliver defensible insights and credible perspectives.

Healthcare providers and life sciences organizations face many compliance challenges. When organizations decide to make a voluntary self-disclosure, our professionals have significant experience in credibly performing the appropriate damages and liability assessments and presenting them for regulatory review. This may include, for example, designing and implementing a statistical sampling approach and extrapolation, and confirming that the sampled units are reasonably representative of the relevant population.