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Case Studies

FCPA Investigation

FCPA investigations sometimes come about as a result of an internal discovery that a company wishes to declare and make public to authorities. Other times, such investigations take place at the demand of regulatory agencies or legal entities.

In this case, the client had received an anonymous message alluding to internal fraud at the company – specifically, the payment of bribes for the purpose of obtaining contracts at one of its foreign subsidiaries.

Our investigative team traveled to the country where the bribes were said to be taking place and immediately began researching the company’s business activity there.

In reviewing the subsidiary’s finances and conducting an independent investigation, our researchers discovered large payments to phantom vendors.

Our team interviewed the local employees in their native language, discovering information that would prove essential to the investigation. We gathered documents and electronic information that was analyzed using IT forensics methods.

Beforehand, we had worked with the company’s General Counsel and its lawyers to establish the parameters of the investigation and determine what material and documents would be reviewed.

The findings of the investigation allowed the company to understand the workings of the improper activity and identify those responsible.


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