GRBusiness
In Fraud and Corruption investigations, Artificial intelligence and data analytics save time, says IT expert
When a legal team needs to find the facts behind fraud and corruption allegations in a government investigation, technology can drive substantial new efficiencies.
By filtering and evaluating vast amounts of information, artificial intelligence (AI) can effectively sort text messages, audio files, e-mail, and other unstructured data into manageable groups; identify potential relationships between parties accused of fraud or corruption; and recognize patterns of frequency or timing, which may support a client’s defense.
Technology-assisted data analysis can provide the diligence and reliable quality control needed to provide the government with conclusions they can trust.
In this interview, a Partner at Hogan Lovells in Washington, D.C., Peter Spivack, explains how the process of gathering, sorting, and evaluating enormous volumes of data has changed, and why skilled human intelligence is likely to remain a required component of an accurate analysis. Excerpt
Where does the data come from in a government investigation, what are you looking for in that data, and how do you use it in your case?
When we do investigations for a client, we’re trying to determine the facts. There’s usually a very vague allegation that comes in, maybe through an internal whistleblower hotline or a subpoena from the government. We have a list of documents that a government entity is requesting, a complaint that somebody called in to a hotline, an anonymous e-mail that reports some allegation, or a news article.
So there’s a certain amount of information that may show us the ballpark, for example, but we don’t know what row and what seat we’re sitting in. We’re trying to determine if there is an issue, and whether it’s the same issue that’s been identified. If it’s a government investigation, what’s the government looking at? What’s the strength of the evidence? What are the legal or regulatory defenses that we can use to advocate? What’s the client’s exposure? And how do we explain this to the in-house general counsel, chief compliance officer, board, audit committee of the board, and outside auditors, to give them an assessment of what the risk is?
And if we’re going in to see the government, how do we explain that we’ve done an investigation that they can rely on and found the relevant facts, or have taken sufficient steps that, based on the sources of information available to us, we can rule things out? Because they’re not going to simply say, we trust you and if you tell us you’ve looked at five e-mails, that’s all you needed to do. We need to be able to tell them that we’ve looked at the whole picture.
Then there are other constituencies that drive investigations, especially for big public companies. Are they trying to get a line of credit? Are they looking at a possible merger where someone may ask them, as part of due diligence, do you have any issues? If you do, what have you done to look at the issues, what steps have you taken to resolve them, and what confidence do we have in the result?
There’s a variety of things that drive us to try to determine what the facts are, depending on the situation, and sometimes they are present all at once.
After determining the approach to the investigation and the data you need, you then have to review the data sources. Where is that data stored?
The way companies keep data is basically structured and unstructured. Structured data is essentially kept in an accounting or enterprise resource planning (ERP) system, such as SAP or Oracle. The data housed there is a record of all the transactions they’ve undertaken, and we’ll work with a forensic accounting firm to define a set of data analytic tests that we can run.
Those tests can be a variety of different parameters we can flag that can be used to show basic fraud or corruption criteria. For example, are there round-number transactions? Are there sequential invoices to the same vendor? It may seem strange that the vendor is getting Invoices 1, 2, and 3, when it’s a vendor that ostensibly would have many other customers. Is there a mismatch in the location of the work and the actual route of payment? Maybe the work is being done in Colombia, but the payment is going to France. We may need to ask for an explanation.
You run those parameters across structured data and come up with transactions that can be tested by taking what’s been journaled in the accounting system and looking at the underlying documents. If you have a contract, does the contract description match the payment description in the system? If there are deliverables under the contract, are they general and vague, or measurable and specific? Can we determine that the transaction has actually taken place?
You can narrow the scope of those data analytics if you’ve got a specific question. For example, we think that this consultant is allegedly paying bribes to government people, so we’re going to look at that consultant, the contract, the signatories on the contract, and the description of work under the contract. We’re going to see what evidence there is of the work. We’re going to look at the payment terms and say, does this seem like something that is commensurate with the value being delivered? Is it a fair market value? We’re trying to hone in and test the bona fides, so to speak, of that contractor business arrangement.
Take an example: one of our clients paid a lot of money to hire a well-known lawyer from another firm. But if you looked at that lawyer, you’d say, he doesn’t really seem to have expertise in that area. So how do you explain that? Maybe there’s a legitimate explanation. But it’s something that comes up and so we say, we want to look at that further. It doesn’t necessarily give you the answer, but it focuses things for you to look at.
What is unstructured data, and how do you use them?
That’s basically the way that people use communications systems. It’s text messages, e-mails, messaging apps like Viber and WhatsApp, and other types of point-to-point encrypted communications. There’s been an explosion of unstructured data — so much more than there used to be.
My first investigation at Hogan Lovells was for a company that was under investigation for promoting its product off label. They had human growth hormone that had a very specific use, and the government was concerned that they were promoting it widely for other unapproved uses. I was literally looking at hard-copy documents and putting them in Redwelds, depending on which paragraph they were responsive to. That was in 1998. Twenty years later, we’d never do something like that, because we’ve gone from 100 boxes of documents to 200 terabytes of data, and one terabyte is enough to fill the U.S. Library of Congress. So there’s got to be some way to manage all that data and filter it.
How do you start narrowing down data?
The first step is collection: you’ve got to go out and actually get it. That means, looking at the e-mail system. If we think of unstructured data as a series of concentric circles, it also means going out one ring and getting devices that people use, like laptops, and imaging their hard drives. And going out another ring if you can, depending on data rules, and collecting peripheral devices — smart phones, external drives, USB sticks — that store data.
So now you have this immense amount of data, more than any team of lawyers could review if they reviewed every single document for the rest of their lives, their children’s lives, and their children’s children’s lives. It’s clearly an unmanageable amount. The only way to address that is to try to process it and get it all in a form that can be managed and filtered. You try to exclude things that may be very data heavy but are of little value: program files, photographs, things that are really large that suck up data storage space. Then you have a set of data that you try to filter.
What techniques do you use in filtering?
The most basic technique is search terms. You come up with a list of words related to the investigation and apply them across the data to see if there are hits for documents that contain those words. Then you’re reviewing them at first and second levels to see if they’re relevant to the investigation. That sounds good, except you may only have narrowed your ballpark to the club-level seats; you’re getting a tighter ring, but it’s still an enormous amount of data.
There are other techniques that can be used as well, such as an algorithm. It’s called technology-assisted review. You’re taking a set of documents and reviewing that set with a subject matter expert on the investigation. They’re going through a thousand documents and saying, this one is relevant, this one is not. You’re essentially training an algorithm and honing it on the computer so that it can then give you a probability-based set of outcomes for the potential relevance of documents. The probability stratifications can be in 10 percent levels, so you have buckets, from a very unlikely probability bucket to a highly likely probability. You might be able to review the first two buckets, so you screen out a portion of your documents that way.
There is nothing available yet that is really AI, but there are ways of doing concept searching with certain applications. One that we use is called Brainspace, and it’s basically a sophisticated form of the algorithm that groups concepts. You can run a set of documents through Brainspace and decide what concepts to look for. If you want to look for “office leases,” it will group documents around that. You get a set of documents that you can then review for the concept of “office leases,” whereas if it’s payments to a particular third party, you can group them around that concept as well. That gives you more ability to target and focus.
A lot of times we’ll run different techniques as a way to cross reference. That helps get through larger amounts of data at a higher and more efficient rate. But at the end of the day, it still depends on human evaluation and intelligence to look at a document and say, this is important, as it’s related to things that we’re talking about, or there’s a particular issue here.
While we’re doing that, you have to remember it’s a dynamic situation, so there may be something that comes out of the transaction and data analytics that then says, wait a minute, we really want to look at this company, so let’s run that as a new term through whichever technique we’re using. Or we may put these documents together for interviews. We have a set of documents, we go to talk to a witness and say, what happened? And they tell us but then they raise another issue. That gets fed back into the review of documents and transactions to see if there is anything here that we have to be concerned about or if a new issue has come up.
Or there might be another whistleblower e-mail that comes in, competitor complaint, or newspaper article. So a lot of times, it’s a dynamic process. You don’t have just a static set of issues that you’re looking at. One of the fun things about it is that there’s this constant evolution.
Who is a typical client in this scenario, and what’s the primary benefit of this approach?
This is a way of making investigations more efficient, and efficiency means cost effectiveness. Clients are getting more and more comfortable with data and techniques of analyzing data, to the point where some clients in their compliance programs not only have lawyers and accountants, but also data scientists. A big multinational client, with tens or hundreds of thousands of employees, has people on staff who can design the most current state-of-the-art search engines, train algorithms, and use them as a way to leverage resources.
It’s the outer edge of clients who have that capability, and they have to be big enough and operate in enough countries that they’ll use it. If they’re not, then we work with forensic technologists, both in-house and at forensic consulting companies. They’re very familiar with different search techniques and technologies and the way to leverage them to process and filter larger and larger amounts of data.
There have been significant advances in technology in the last few years, and more and more interest in it. A lot of it is because of the ever-increasing amounts of data, and as a result, ever-increasing cost. There have to be ways to get costs to a controllable, reasonable level. So we have to know how to do that and work with people who understand and are comfortable with the concepts. We have to be able to articulate both to the client — if they’re unfamiliar with it — and to the government — to defend it — what we’re doing, how we’re doing it, and why it’s reliable. The government uses these techniques as well, so most of them are very familiar with it. They just want to make sure there’s a sufficient level for liability.
About Peter S. Spivack
Peter Spivack is one of the most experienced members of the Investigations, White Collar, and Fraud practice area, and served as a global co-leader of the practice for six years. His experience in the criminal arena includes antitrust, environmental, Foreign Corrupt Practices Act (FCPA), government contract, and healthcare matters. Peter has three decades of experience working with multijurisdictional investigations, including matters involving allegations of bribery and corruption under the FCPA, the UK Bribery Act, and other anti-bribery laws.
Key players and experts in Nigeria’s oil and gas and power sectors have called for concerted measures and actions that will lead to property utilization of the country’s vast gas reserves.
Key players and experts in Nigeria’s oil and gas and power sectors have called for concerted measures and actions that will lead to property utilization of the country’s vast gas reserves.
They expressed the opinion that Nigeria’s gas reserves are critical asset towards achieving the ongoing energy transition that will be affordable and sustainable.
Speaking at the 4th Oriental News conference in Lagos on Thursday July 24,2025 themed’ , “Integrating Nigeria’s Gas Potentials into Strategic Energy Transition Initiatives,” the Manager, Energy Transition NLNG, Temitope Ogedengbe, advised that Nigeria must avoid adopting a “copy-paste” approach to energy transition, insisting that the country must tailor its strategy to reflect local realities, including the urgent need for economic growth, energy security, and national development.
“Our transition must leverage our unique strengths and resources to grow our economy,” Ogedengbe said. “Energy transition should not be a copy-paste exercise.
“Nigeria must design its own, since we need economic development, energy security, and to address developmental issues.”
Ogedengbe, while highlighting challenges around gas utilisation, lamented that despite Nigeria’s abundant natural gas resources, a large portion is still being flared or reinjected due to the absence of viable commercial arrangements.
“We’re not taking nearly the amount we should be. We are still failing and reinjecting because there is no commercial arrangement to optimise this; for many reasons,” he stated.
He noted that while marginal fields hold potential, they are difficult to produce economically.
“The issues there are marginal fields, which are difficult to produce,” he said, adding that the Nigerian Upstream Petroleum Regulatory Commission’s (NUPRC) Gas Flaring Commercialisation Programme is trying to address this.
According to him, a significant chunk of Nigeria’s gas is still either exported or flared, while domestic utilisation and value addition remain underdeveloped.
“We are not investing enough, and we are not examining the right approaches,” he added.
Speaking on the global LNG market, Ogedengbe noted that although there is still a market for LNG produced by Nigeria, demand patterns are shifting, particularly in Europe, where buyers now favour lower-carbon LNG options.
He said, “There is still a market for LNG produced in Nigeria, but what is happening is that Europe is asking for lower-carbon LNG.
“There’s a need to use operational levers to reduce carbon, attract premium markets, and unlock funding opportunities, including through reduced taxes and levies.”
He further stated the NLNG remains central to Nigeria’s gas future, revealing that the company plans to expand its capacity to 30 million tonnes per annum.
” As part of its energy transition strategy, the company is integrating technologies and processes aimed at reducing emissions and generating carbon credits.
“We’re using offsets to reduce our emissions, both at the national and international levels, to take carbon out of the atmosphere and promote our operations,” he explained.
Ogedengbe emphasized the need for a multi-pronged, well-coordinated approach to decarbonising the country’s gas sector to ensure long-term viability and global competitiveness.
Also, at the same conference, former Power Minister, Prof. Bart Nnaji said that shortage of gas supply and infrastructure deficit has continued to act as disincentive to investment and growth of the power sector.
Nnaji, said in the next two decades power generation in the country will be dominated by gas fired plants.
He attributed Nigeria’s persistent gas shortage to inadequate investment in gas infrastructure and called for more support from both government and the private sector.
Nnaji, who chaired the event, addressed stakeholders from across the oil and gas value chain, including key government officials.
He said the country’s gas sector remains underdeveloped due to insufficient investment in extraction, transmission, and transportation.
“The focus should not rest solely on government-led efforts — the private sector must also play a vital role,” the former minister said.
“What we need is for the government to act as a true enabler, offering the necessary support for infrastructure and gas harvesting. It’s baffling that with over 210 trillion cubic feet of gas, we still face local shortages.
“We’re unable to produce sufficient quantities to support operations across the country. Though operations improved this year, they weren’t previously at full capacity. A seventh train is underway, but we need more gas.”
He said Nigeria’s history of mining and exporting coal before abandoning it reflects a wider pattern of resource neglect.
Nnaji said gas-fired plants are critical to Nigeria’s power generation, emphasising the need for a reliable supply to ensure thermal plants operate effectively.
He noted that Geometric Power Ltd, which he chairs, is among the companies generating electricity through thermal sources.
“For effective supply from thermal plants, an adequate and reliable gas supply is vital. While we have hydro power, gas-fired plants remain dominant and will likely stay that way for the next ten to twenty years,” he said.
Nnaji acknowledged the role of renewable energy in rural electrification but maintained that Nigeria’s baseload power must continue to come from gas or hydro sources.
He noted that hydro power, however, comes with limitations that require regional cooperation.
In her submission, Engr. Chichi Emenike, Acting Managing Director and Gas Asset Manager of Neconde Energy Limited, sounded alarm over the consequences of some policies of Government that has undermined the ongoing energy transition.
According to her, unpaid gas supplies, dollarised operations, and policy inconsistencies are discouraging investment in the sector.
Emenike, said Neconde, for instance, has gas that has been produced and supplied to the electricity generation companies (GenCos) and that has not been paid for almost two years now.”
“This is a serious conundrum, whereas we have sourced funds from somewhere to produce these gas molecules from our facilities. How am I going to pay back?”
Emenike further explained that Nigeria’s upstream gas production is highly dollarised, making it costlier than crude oil development and difficult to sustain without a commercially viable framework.
“Don’t forget that the gas production industry is highly dollarised, including the requisite inputs. There is no part of the operation, including the technology, that is produced locally. The bulk of it has to be imported in US$.
“The O&M, well drilling, and accessories to drill a gas well are all dollarised. So, it costs more than what it costs to drill a crude oil well. The handling of a gas well is highly sophisticated, unlike that of crude oil.”
Speaking on systemic issues within the gas-to-power value chain, Engr. Emenike said, “Over 500 million standard cubic feet (scf) of gas are being transported with the NGIC pipeline.
“If you multiply this figure by one dollar, you will understand the cost. Whereas so much money went into drilling some of these wells, it costs $35,000 plus or minus, and that is outside other assumptions of fees.”
Commenting on the financing and investment environment, Emenike called for a pragmatic national energy plan that begins with achievable goals, rather than lofty ambitions.
“Let us start with what is doable; I mean the low-hanging fruit. Let us stop with big numbers. We should tidy up small fields that are struggling to juggle both CAPEX and OPEX.
“We need to sit down once as a nation to be selfish enough to determine what is needed to take care of Nigeria’s economy alone in the Gulf of Guinea.”
She called for urgent clarity on Nigeria’s position in the energy transition and a realistic approach to funding.
“Where do we sit as Nigerians today on this energy transition plan? Where is the money to run the transition?
“Presently in Nigeria, it is difficult for a gas investor to determine end-to-end where the funds would be coming from. We need a strategy; we need to be serious. Or else, gas investors would rather take what they should have invested in the Nigerian economy to Mozambique or elsewhere.”
Emenike further warned about the economic risks associated with policy instability.
“Gas economics is such that it must be end-to-end. Even before you draw down the first financing, you have tied that investment to a commercial arrangement.
“When you have a business, as much as you think you know, in the case of Nigeria, once you put your leg out in this economy, you will see so many things flood in unexpectedly. Your IRR (rate of return) goes down the drain due to policy flip-flops and multiplicities of levies and fees.”
She insisted that the sector needs regulatory reforms and an end to what she described as rent-seeking behaviour by government agencies.
“We have to deal with the rent-seeking attitude of our regulators to enable investors repatriate their investment financing.
“They should stop flogging investors with all forms of regulations and later charge them with potential incidents of non-conformity, which translates to fines, even for not operating, after they have created the crisis.”
Calling for collaborative efforts, she advocated infrastructure sharing and coordination within the value chain.
“We need to leverage infrastructure to unlock the stranded assets across the country. We need to look at how to put together our war chest to achieve a lot for the industry. We need to set the rules of the game.”
She emphasised the importance of investor confidence and a market-driven approach.
“Every investor wants to see a clear line of sight. Market forces should be allowed to play out. The government should not create a monopolistic environment that stifles investment. They should allow it to have that flexibility.”
“None of these government officials understand how investors raise capital to finance their projects and the terms of it. Government has no business in business. They should stop the rent-seeking attitude and stop looking for short-term benefits. Quick fixes will not work.”
She has therefore challenged the FG to focus inwardly and begin with achievable solutions.
According to her, “There is much more to be gained if we have a very selfish Nigerian plan that focuses on Nigerian interests alone. This can service the entire Gulf of Guinea if we are serious. Let us start with the small gas fields.
She further urged the FG to stop putting benchmarks on gas for power, adding that the market forces should be allowed to dictate the price.
Engr. Emenike charged the Nigerian government to allow flexibility in the market and encourage alliances within the value chain operators.
Finance
NGX Boss, Umaru Kwairanga, to Chair Business Journal Fintech Roundtable 2025
By Our Correspondent
Dr. Umaru Kwairanga, Group Chairman, Nigerian Exchange Group (NGX) will Chair the 2nd Business Journal Fintech & Financial Inclusion Roundtable 2025 scheduled for Friday, August 29, 2025 at Oriental Hotel, Lekki, Lagos. Time is 10-am prompt.
The theme of the Roundtable is: Fintech & Financial Inclusion: The Opportunities & Challenges for Nigeria.
In a statement, Prince Cookey, Publisher/Editor-in-Chief of Business Journal Media Group said the choice of Umaru Kwairanga to chair the event is a reflection of his immense and chequered journey in the Nigerian economic system over the years.
“Dr. Umaru Kwairanga is a noted player in the Nigerian economy and financial services sector. Over the years, he has carved a positive niche in driving the narrative in national policy formulation, implementation and review. He remains a worthy point of reference and role model to current and future players in the Nigerian economy.”
Alhaji (Dr.) Umaru Kwairanga, Sarkin Fulani Gombe and Group Chairman, Nigerian Exchange Group (NGX), is a notable player in the Nigerian corporate world, a thorough-bred professional and a prominent community leader in Gombe State and the North East region.
He has served at the highest levels of the banking, pension, investment, manufacturing and commercial sectors of Nigeria’s economy. He is the current Chairman of the Nigerian Exchange Group Plc, Nigeria’ oldest stock exchange and also Chairman of Tangerine General Insurance Limited.
The NGX Chairman is also a Director on the Boards of First Bank Senegal Limited, Tangerine Apt Pensions Limited and the Group Managing Director of Finmal Finance Services Limited.
He is a past Chairman of Ashaka Cement plc and previously served on the Boards of Jaiz Bank Plc, Central Securities Clearing System Plc, Lafarge Africa Plc and First Bank Mortgages Limited to mention a few.
Professionally, Alhaji Kwairanga is a Fellow of the Chartered Institute of Stockbrokers, Chartered Institute of Directors of Nigeria, the Certified Pension Institute of Nigeria and the Abuja Commodities and Securities Exchange.
He is also a Council Member of the Chartered Institute of Stockbrokers; the Chartered Institute of Directors and he is the current President of the Certified Pensions Institute of Nigeria.
Kwairanga is a holder of the prominent traditional title of Sarkin Fulani Gombe and has led several initiatives for peace and development in Gombe State and the North East region in general.
He has also been involved in policy and strategy formulation in the public sector as a Member of the Vision 2020 Committee, the Presidential Advisory Committee on the Nigerian Industrial Revolution Plan and several committees of the Securities and Exchange Commission (SEC).
Transport
Enugu Air, CNG Buses, Transport Terminals Take off in May
… Govt set to develop tourist sites, reports SANDRA ANI
… Work starts on Nnamdi Azikiwe Stadium, Awgu Games Village in earnest
The Enugu Air, CNG Mass Transit Programme, and the ultramodern transport terminals all built from scratch by the Governor Peter Administration are to be launched for operation before the second anniversary of the government.
The government has also approved the development of the state’s tourism industry, while total transformation of the Nnamdi Azikiwe Stadium and Awgu Games Village will start in June to get them ready for the National Sports Festival to be hosted by the state in 2026.
These were made known by the Commissioner for Transportation, Dr. Obi Ozor; Commissioner for Culture and Tourism, Dame Ugochi Madueke; Commissioner for Works and Infrastructure, Engr. Gerald Otiji; and Commissioner for Youth and Sports Development, Barr. Lloyd Ekweremadu after the State Executive Council meeting at the Government House, Enugu, at the weekend.
Briefing Government House Correspondents, Ozor said, “We are starting off with the initial three aircraft and two of the aircraft are already on ground. The third one will be on ground by the end of this month. We are hoping to start the commercial operations before the second year anniversary of this administration.
“You have also seen buses for the mass transit programme across the state. 50 of them are already parked at Okpara Square, and an additional 50 will be joining that fleet in the next few weeks. The 100 of them will be going into commercial operations before the end of this month, which is the second year anniversary.
“Also, the bus terminals, two at Holy Ghost, one each at Gariki, Abakpa and Nsukka, will also be commissioned and go into commercial operations before the 29th of May, this year.”
He added that the government planned to bring in the electric and CNG automotive manufacturing plant into Enugu as well as launch in the next 150 days the Enugu Smart Transport Programme, which would see to the injection of over 2,000 electric vehicles.
Also briefing newsmen, Dame Madueke said funds would be invested in the tourism industry in phases.
“We are going to have it in phases. For the first phase, we are having Awhum Waterfall, Nsude Pyramid where we are going to have the first canopy walkway in the South East. It measures about 600 metres, which will actually be the longest in Nigeria.
“We also have Ngwo Pine Forest where we are having the first zipline in Nigeria. The zipline will measure about 300 metres. In the same Ngwo, we will have a big rotunda and a smaller rotunda. We have the Cross of Hope to be located at Okpatu. The Cross of Hope will be sitting 580 metres above sea level and the cross itself will measure about 50 metres, making it a total of about 630 metres above sea level. The cross will have about 15 floors with a lift.
“At Awhum Waterfalls, we are going to have another canopy walkway and a boardwalk to preserve the ecosystem.
“We equally have the Akwuke/Atakkwu Waterpark and Ovu Lake Golf and Resort at Akpawfu,” she stated.
She explained that all the tourist sites would have experience centres, food courts and renewable energy, adding that tour buses would soon arrive to ensure ease of movement of tourists.
Ahead of the 23rd edition of the National Sports Festival, Enugu 2026, Barr. Ekweremadu said the State Executive Council had equally directed the commencement of work both at the Nnamdi Azikiwe Stadium and Awgu Games Village not later than June.
“We also briefed the council on the progress made in establishing a Lab for Animation for young people in Enugu State, which His Excellency will be commissioning soon. The lab is ready.
“We are similarly working towards empowering over 2,100 young people across the state, who were trained around December last year. This empowerment will be coming up on the 12th of August, being the International Youth Day’” Ekweremadu concluded.
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