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.
… Plant to create 5,000 jobs, produce 100 cubic metres of oxygen, 45 cubic metres of acetylene per hour
… Nitrogen, argon gas; carbon dioxide, CNG Stations in the pipeline
… Dr. Uduji: Mbah, Nehemiah of our time, rebuilding broken walls
…Kanayo O. Kanayo: Security is working in Enugu
Governor of Enugu State, Dr. Peter Mbah, on Thursday, unveiled Nigergas Company Limited, revamped and upgraded by his administration after over three decades of dormancy.
Mbah said Nigergas had so far created direct employment for over one hundred skilled and semi-skilled workers, and would further create over 5,000 indirect jobs across distribution, fabrication, transport and supplies chain.
He stressed that the revival of Nigergas company, which was established in 1962 as part of Dr. Michael Okpara’s after decades of abandonment, was another proof of his administration’s commitment to reviving state-owned moribund assets and grow Enugu State’s economy from $4.4bn to $30bn.
“What we have revived and unveiled today is not simply metal and a network of pipes; it is the restoration of purpose, dignity and productivity to a site that once symbolised Eastern Nigeria’s industrial promise.
“When we speak of the goal to grow our GDP from $4.4bn to $30bn, it is not mere posturing. It is rooted in the conviction that Enugu can become a truly diversified, self-reliant economy, if we muster the will to do things differently to launch us to the future we dream of,” he stated.
On Nigergas’ rehabilitation model, capacity, and expansion plan, Mbah said, “we approved a full rehabilitation scheme and a management model that blends public ownership with private-sector performance discipline.
“The intention was clear: retain public ownership, but run the facility on modern, accountable, commercially viable lines.
“So, today, Nigergas returns to production with modernised equipment and clear technical specifications designed to meet immediate healthcare and industry needs.
“The plant’s installed capacity has been upgraded to produce significant volumes of medical and industrial gases, ensuring steady local supply and reducing dependence on distant, expensive suppliers.
“Crucially, the plant will supply liquid oxygen, medical and industrial oxygen, and acetylene gas to our hospitals, welders, agro-processors and manufacturers, improving clinical outcomes and reducing production costs for businesses that are the backbone of local livelihoods.
“The new plant has a capacity to produce 100 cubic metres of oxygen per hour; and 45 cubic metres of acetylene per hour.
“We will soon bring on stream these additional products: nitrogen; argon gas; carbon dioxide; and CNG stations,” he said.
He maintained that Nigergas’ revival would guarantee access to reliable medical oxygen saves lives, on-demand industrial gases to lower operating costs, speeds turnaround and keeps workshops and factories turning.
“These improvements ripple outward: increased industrial activity strengthens our revenue base, and deepens opportunities for MSMEs,” he said.
He commended the Managing Director of the Enugu State Investment Authority, and the Commissioner for Trade, Investment and Industry, Dr. Sam Ogbu-Nwobod; the engineering firm, Ten Gas Development Ltd (a division of INDEV GROUP and the community leaders of Emene for their roles in resurrecting Nigergas.
speaking, Dr. Ogbu-Nwobodo expressed joy that although the firm established by Dr. Okpara Administration in partnership with Siad Machine Impianti was abandoned for over three decades due to mismanagement, misappropriation of revenue, abuse of company resources, nepotism, and weak corporate governance, Governor Mbah had restored the lost dreams.
The Managing Director, Ten Gas Development Ltd., Chief Chike Madueke, noted that the restored Nigergas would provide training and thousands of employments for the youths of the state.
The Chairman, Enugu State Traditional Rulers Council, Igwe Samuel Asadu; community leader and health consultant, Dr. Joy Uduji; Chairman of Enugu East LGA, Pastor Beloved Dan Anike and a businessman, Engr. George Ndubeze Ugwu, also commended Mbah for not only breathing life into dead state-owned assets, but for also building infrastructure that make lives better and enable businesses to thrive.
“You are the Nehemiah of our time. Like Nehemiah, who came and supervised the rebuilding of the walls of Jerusalem, you have also come to rebuild Enugu State,” Dr. Uduji said.
Speaking, Nollywood veteran actor and movie produce, Kanayo O. Kanayo, said, “It is not praise-singing, security is working here because when I come to make movies here, we usually stay out late into the night at Nike, and we are safe.”
Transport
August24news Publisher, Ajagbe, Set to Present Best Driver and Best Conductor of The Year Awards
As part of efforts to sanitize and project the image of the transportation system in Lagos State and ability to reward good deeds and eliminate the bad eggs among the drivers and conductors in the state, Lagos-based frontline journalist and publisher of Nigerian Online Newspaper, August24news.com, Mr. Ajagbe Adeyemi Teslim is set to present the best driver and best conductor awards to deserving professionals in the state.
The competition is expected to start in January 2026 and end by December 2026 and it has been designed to be a yearly competition after the maiden edition.
The parameters and measures put in place to pick the Best Driver and Best Conductor in the state is through commuters’ commendations, score cards, online voting system by the general public, public opinions and other relevant methods.
Many drivers and conductors in Lagos State are known for their lackadastical attitudes, but there are still good ones among them, which is the reason we want to reward the good ones among them so that the wrong ones will emulate from the rewarded ones.
Speaking at a press conference in Lagos, the convener of the Award and Publisher of August24news.com, Mr. Ajagbe Adeyemi Teslim highlighted some of the marks expected in every drivers and conductors before winning the awards.
He said they must possess good characters, good dress sense, good driving skills, saying that drivers and conductors must charge their passengers reasonable transport fares, possess good communication skills and relate well with their passengers, they should avoid stoping at undesignated bus-stops, avoid handling our naira with care because the way they are mishandling our naira is one of the reason why our currency is fading and changing faces.
In addition, he said that they should avoid bribing officials of the Lagos State Traffic Management Authority (LASTMA) and other road transport officials because they want to have their ways, they must receive and welcome their passengers with smiles and greetings, avoid pushing and roughhandly their passengers into and outside the bus, they must not smoke and drink before or while on duity.
He said they should be able to help passengers with free ride if the person pleads with them and they should not fight passengers whose fare is not completed, they must not make calls while driving, they should sit properly and avoid hanging on the bus, avoid picking passengers at unapproved bus stops and his or her bus must be in good condition before plying Lagos roads.
On what would be the benefits of the winner, Ajagbe stated that the winner will go home with over dozen gifts which include, a brand new bus, a brand new private car, a duplex, free 20 liters of fuel daily for a month, twenty four million naira cash, brand ambassador contract, driving contract, tour of 10 notable places in the state, courtesy visit to 10 dignitaries in Lagos State, automatic employment for two of his children in Lagos State, 24 different native and English attires from a popular designer, 24 new tyres, an award plaque, conductor and driver bet, a befitting gala night and Letter of commendation from the Lagos State Government, adding that the best conductor will also get whatever the driver gets.
When asked about what prompted the idea, the publisher said that he had witnessed many ugly incidents among Lagos drivers and conductors, which he said made him think of a way to change the narrative and to rebrand the profession.
According to him, “we want to put them on the watch, we want to set an agenda for them, we want to curb thier lakadastical act and non-challantant attitude such as drinking and smoking while on duty as well as reward the best among them, eradicate the bad ones and also encourage others so that they can be emulated.
He added that there is no agency that monitors thier activities in the state, claiming that what the National Union of Road Transport Workers (NURTW) and local governments does is just to collect fees and levies from them.
Speaking further, he said; “I have witnessed a situation where drivers and conductors beat passengers because of a mere 10 naira change during argument.
“I have witnessed, where drivers and conductors abused and insulted passengers which led to trauma. I have seen where a passenger was stranded, trekked home and even begged for transport fares simply because a wicked conductors took his change away. I have seen where people where properly dressed, clean and neat, unfortunately a public bus tore and dirty thier cloth. These are people who are set for their daily jobs, going for job interviews and attending social gathering.
He said that on numerous occasions, he had seen situations where conductors and drivers returned lost phones, gadgets, loads and even bags of money to their passengers, saying that “we must not shy away from the truth or be economical with the truth, the good ones are still living and must also be recognized and rewarded.”
“I have not seen when conductors give passengers free ride out of the 365 days in a year. Some of them are not friendly with their customers, they should be able to give back to the society or their passengers and they should be ready to partake in CSR. Anyone who does this will win the award of the year,” he said
When asked what his organisation stands to benefit from the awards, Ajagbe told newsmen that his target are numerous because “we want the best for Lagos State and Nigeria as a whole. We want them to be responsible and accountable to their passengers and the general public. We want commuters to get value for their money, We want them to be good ambassadors because foreigners and the international communities see their practice.
“We want to set an agenda for them, we want to change the narrative, we want to change the public orientation that public bus drivers and conductors are respected people and not bad people as people see them.
“Some of them are always the cause of accidents on our roads due to their lakadastical attitude. We want the government to put them on a good pedestal. We want them to put a stop to their hooliganism and fighting during the cause of their business.
“The NURTW and the local governments are levies collectors. We want the state government to mandate drivers and conductors to start wearing uniforms and have numbers to identify the erring ones among them,” he stated.
Speaking on the measure and yardstick to pick the best driver and best conductor among the thousands in the business, Ajagbe stated that members of the public will engage in voting after evaluating all the requirements.
The drivers and the conductors will also appeal to their passengers to vote for them via hard copy forms, sms text code and online voting.
Ajagbe said that all commercial buses drivers and conductors in Lagos State are eligible to participate in the competition because it is free, adding that no payment is required to participate in the competition once he or she is a registered member of the union in a specific garage attached to a route in Lagos State.
When asked if the project will fly and accepted by members of the public and even get sponsors, Ajagbe said that 90 percent of Lagosians ply public busses on a daily, weekly, monthly and yearly basis to their various destination and they must have had one or two experiences with some of these drivers and conductors and they will be willing to share their positive or negative thoughts.
He stressed that the job is taking a new look and dimensions, particularly when it’s coming with rewards and that sponsors are always keen to assist creative ideas and concepts like this.
“We would work in hand with the Lagos state government, the state Ministry of Transportation, Lagos State Branch of the NURTW State, local government branch and Unit Chairmen, drivers and conductors association and other relevant agencies attached to transport business in Lagos state”. Ajagbe added.
Ajagbe revealed that the whooping sum of one billion naira (1.000,000,000) is proposed for the project and then called on the Lagos state government, the ministry of Transportation, corporate bodies, well meaning Nigerians to key into the idea and response promptly to the proposal sent to them as he can be contacted through; [email protected] for sponsorship and partnership to produce the best Driver and Best Conductor in Lagos State.
Commenting on the project, is former LAGOS State commissioner for Transportation, Hon. Dr. Muiz Banire (SAN) stated that it is a laudable project that will add honour to the work of the commercial bus drivers and conductors in Lagos State as he kindly appealed to sponsors to fully support the project.
Finance
Tinubu Launches Personal Income Tax Calculator to Improve Compliance, Fairness
By ORJI ISRAEL
President Bola Tinubu has launched a Personal Income Tax Calculator to help Nigerians work out their tax obligations under the new tax law.
The tool is expected to make compliance easier and improve transparency in the system.
In a post on his X page, the president said the calculator shows how the recent reforms protect low-income earners while ensuring fairness.
“A fair tax system must never punish poverty or weigh down the most vulnerable. With the new tax laws I recently signed, taking effect from January 2026, we have lifted this burden and created a path of equity, fairness, and true redistribution in our economy,” Tinubu said.
Some months ago, he signed four major tax bills into law to bring Nigeria’s scattered tax system under one framework. These include the Nigeria Tax Administration Law, which sets out a uniform process for tax administration across federal, state, and local governments; the Nigeria Revenue Service (Establishment) Bill, which replaces the current Federal Inland Revenue Service Act with a stronger, more independent revenue agency; and the Nigeria Revenue Service (NRS) and Joint Revenue Board (Establishment) Bill, which creates a formal structure for cooperation between revenue bodies at all levels.
The introduction of the tax calculator, together with these reforms, is expected to reduce confusion for both individuals and businesses, while also making it easier for them to meet their obligations and contribute to national growth.
Tinubu added that the reforms are part of building renewed hope for the economy and urged Nigerians to trust in the country’s future for themselves and their families.
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