Got a compliance issue? Anheuser-Busch InBev, the world's largest brewer of beers, has an app for that, serving its 205,000 employees spread throughout 90 countries around the world.

The compliance app and website were part of innovations undertaken by the legal department at the Leuven, Belgium-based brewery that is home to some of the world's most famous beer brands, including Budweiser, Corona and Stella Artois. The department's unconventional and high-tech strategies, carried out on a truly global scale, earned it the 2018 award for Best Legal Department in the compliance category.

As has happened at other companies, a high-profile merger spurred big legal department changes. In October 2016, AB InBev, as it is called, acquired London-based SABMiller in a $100 billion deal. The acquisition added 50,000 employees and 65 more countries to AB InBev's operations.

General counsel John Blood says the legal department faced a massive three–part challenge: integrating compliance into every function of the new company; making the compliance program quickly accessible to every employee in every country; and, gauging and managing compliance risks in countries where AB InBev had not previously operated.

“We needed to do our due diligence and know the compliance space in Africa, Australia and other countries where we had little or no experience,” Blood says. “The traditional way would be to hire teams of accountants and lawyers at a high cost to go into each operation and do a full-scale books and records investigation.”

But Blood's team did not take the traditional path. His team, including global legal director Matt Galvin and global compliance/antitrust/litigation head Martim Della Valle, were already pushing to invest in more data analytics. For much less money, they envisioned aggregating all accounting and compliance data into a central analytics platform that would live and grow with the company.

Instead of sending teams of professionals all over the world to collect data, the legal team brought the data to it. They designed investigations and due diligence software and rolled the technology out to every operation across the world.

“And instead of coming out of it with a big report in a binder,” Della Valle says, “we built an ongoing program to help take our compliance program to the next level.”

Called BrewRight, the program includes algorithms and dashboards to use as tools going forward, as well as artificial intelligence that allows BrewRight to learn from past behavior. The last time AB InBev did a deep due diligence investigation of this type, it cost the company $1.8 million. With BrewRight, built with in-house talent working with outside coders and vendors, it only cost $200,000.

Galvin says the legal team can use the new system to look at sales conduct in Ghana, or how much cash is on hand in Algeria, or who the biggest vendors are in Brazil. “We can aggregate and risk score every vendor and every transaction in the world,” he explains.

The lawyers can also use the analytics in other ways, such as to compare internal investigations to see if one investigator takes much longer than others, or to spot trends in areas like sexual harassment complaints.

“We can also get a composite risk score,” he says. “We can score every one of our operations for corruption, fraud, money laundering and such, then choose to put our resources where the highest risk is.”

Galvin sees the system as being in year two of a five-year plan. “As the case management system teaches and gets smarter, the underlying data will get better, transparency will be magnified, risk scores more accurate using a regression analysis,” he says.

The next big step, Galvin says, is predicting fraudulent behavior before it happens. Blood, the GC, explains that the system now can red flag an unusual payment, say, from its size, or round numbers, or lack of backup documentation. When the compliance team further investigates, it enters false hits and positive hits so that the system can learn.

“The next step,” he says, “is before a payment is actually made, the system would be able to predict [possible fraud] because of something about the payment, its nature or timing, or something about the vendor. It won't say proper or improper, but it would say to inquire more.” Blood says he was fortunate to have a legal team that “has a passion for data analytics and for working with the information technology team.”

At the end of the day, Blood adds, “your data is only as good as the humans who make judgments about where to look, how to analyze it, when to tweak it, what is meaningful and what isn't. Many factors go into it. It is very much a human process.”

The compliance team is made up of about 60 professionals, including lawyers, accountants and computer scientists. IT is part of the compliance team, Galvin explains.

The company further emphasizes compliance by tying it to other objectives that employees must meet to receive bonuses. “We are very good at attaching hurdles and compliance challenges to bonus payments,” Galvin says.

In addition the legal team last year completed and rolled out an application called Compliance Channel. It includes a website platform that supports the whole compliance program and an app available in both Apple's App Store and Google Play—making the program easily accessible to every employee.

Through the app, everyone can see or upload all of the company's policies as well as have access to the anonymous whistleblower helpline.

So far the greatest use of the app, Galvin says, has been in Africa. “It really helped 14 businesses there right away,” he says.

Data about possible risks flows into the website from countries around the world, and the website generates advice on the compliance implications, including raising red flags if necessary or asking for more information. There is also a workflow for analyzing new suppliers depending on their risk levels.

Della Valle says the legal team also used the technology to do a substantial antitrust risk assessment and took a number of remedial actions. “This is permanent, and we will keep doing it every year moving forward, refreshing the exercise and addressing potential new issues and concerns,” he explains.

Della Valle says he is working on a pilot project in Europe to take compliance even further, using behavioral science. The key is better understanding how to influence the choices that people make, so that, in effect, the default choice is also the compliant one.

“I truly believe this is the future of compliance,” he says.

For their herculean efforts, AB InBev's in-house team won a 2017 Financial Times award for innovation in data, knowledge and intelligence.

And Blood is always ready to talk to other GCs about the system. “Ultimately, our vision is to share it with others,” he says. “We think it could be a solution for other companies.”