FCPA enforcement was moving down-market, and mid-sized companies had nowhere affordable to turn. The DOJ and SEC had pursued enforcement aggressively, with violations routinely resulting in penalties and settlements in the tens of millions of dollars, and investigations were increasingly migrating to smaller companies, not just the large multinationals traditionally targeted.
“Anytime company executives read about the FCPA there is a multi-million dollar figure next to it. This is totally unrealistic for companies of this size. They know they have a problem, but don't know how to solve it. The result has been compliance paralysis.” — FCPA Practice Lead, Partner
Clients recognized the risk but didn't want to hire compliance staff in-house, and were priced out of hourly outside counsel.
The challenge was one most firms serving mid-market clients will recognize: companies knew they were exposed, but nothing on the market let them act on that knowledge affordably. Clients with international operations could see the risk the FCPA posed. What they couldn't justify was the cost of solving it: hiring in-house compliance staff, or paying outside lawyers by the hour for open-ended guidance.
The friction was predictable. Traditional hourly counsel priced out the companies most exposed to risk. In-house compliance hires were too costly to justify for mid-market operations. Generic compliance consultants offered frameworks without legal protection or accountability. And companies needed practical implementation guidance, not another risk memo.
The firms winning this market weren't the ones with the deepest FCPA expertise. They were the ones who could deliver it at a price and pace mid-market companies could actually act on.
The firm decided the answer was to design and develop a technology-powered offering from the ground up: one that combined privileged legal advice with automation software, delivered for a fixed annual subscription fee, including unlimited “curbside counseling” on FCPA issues as they arose. No hourly surprises, no generic playbooks, no compliance paralysis.
For the client, unpredictable hourly billing became a fixed annual subscription with clear scope from day one, unlimited access to privileged legal counsel, and risk assessments compressed from months to weeks.
For the firm, attorney expertise is encoded directly into the platform, so it scales without scaling headcount: knowledge captured once and delivered repeatedly, reaching clients who couldn't previously afford this level of counsel, as a repeatable service instead of one-off engagements.
Neota's no-code platform let the firm encode attorney knowledge directly into a system it could then offer to a much larger group of clients. FCPA compliance starts with a risk assessment tailored to the company's specific exposure; using Neota, GRS collects client-specific information and presents it in a clear, organized format, compressing a process that would ordinarily take months into a couple of weeks.
A curbside-counseling module captures the same information a firm lawyer would otherwise gather in a live client conversation. Responses that raise a caution flag, for example questions about entertaining a foreign official, route the client to a firm attorney for individualized counsel, keeping expert judgment in a governed system without compromising quality or control.
GRS launched in early 2015, combining business and compliance risk assessments, current policies and procedures, officer and employee training, and ongoing access to legal counsel, all delivered for an annual subscription fee. Most companies were up and running with a working FCPA compliance program within a couple of months of adoption.
The offering exceeded the firm's internal projections in its first year. GRS received the Wisconsin State Bar Association's Legal Innovator Award in November 2015, recognizing leading innovations in legal service delivery, and also took the 2015 Innovation Quotient award from BizTimes Milwaukee.
“The genius of Neota's technology is that it is amazingly powerful and yet extremely simple to use. They have figured out how to leverage the true capabilities of expert systems technology into a toolkit that makes it easy for any non-technical team to deploy.”
Partner
FCPA Practice Lead
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Book demoCase study · Global Risk Solutions
Global Risk Solutions (GRS) is an award-winning compliance offering from a leading international law firm, recognized for thirteen consecutive years on the BTI Client Service A-Team and ranked among the top 10 best-branded firms in the BTI Brand Elite survey.
Partnering with Neota Logic, the firm encoded its FCPA expertise into a governed platform and delivered it for a fixed annual subscription, reaching mid-market companies that were priced out of traditional hourly counsel, and turning a practice area into a repeatable, scalable service.
FCPA enforcement was moving down-market, and mid-sized companies had nowhere affordable to turn. The DOJ and SEC had pursued enforcement aggressively, with violations routinely resulting in penalties and settlements in the tens of millions of dollars, and investigations were increasingly migrating to smaller companies, not just the large multinationals traditionally targeted.
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