Brian Busby, former Chief Operating Officer of Houston Independent School District (HISD), and vendor Anthony Hutchison are on trial facing charges including conspiracy, bribery, and wire fraud. The indictment alleges that Hutchison overbilled HISD for services like lawn mowing and mulch, with the excess funds used to bribe Busby through cash payments and home remodeling projects. Hutchison reportedly maintained a “bribe ledger” detailing payments. In 2017, payments of $38,000 and $50,000 were allegedly made to Busby for specific projects. The scheme resulted in millions in losses for HISD.

Missing Controls:

• Lack of Vendor Due Diligence: No robust screening process for vendors to detect conflicts of interest.
• Weak Financial Oversight: Overbilling and fraudulent payments were not flagged in real time.
• Absence of Procurement Audits: No periodic reviews of contracts and payments to detect fraud patterns.
• Inadequate Whistleblower Protections: Employees may have feared retaliation for reporting suspicious activities.

How D360 Can Help:
Implement a vendor risk assessment framework to screen and monitor third-party contractors.
Develop AI-driven expense tracking systems to detect anomalies in billing.
Conduct regular forensic audits of procurement transactions.
Establish a secure whistleblower hotline with guaranteed anonymity.