Corruption Related Investigations
We have significant expertise in every stage of the investigation of corruption and conflict of interest matters. We use a pragmatic methodology in forming a sound investigative plan to approach each matter individually based on the known fact and circumstances. We have advised and assisted outside counsel on some of the largest corruption investigations brought by the United States Government. Our investigations include performance of accounting records and business transactions, identify control weaknesses and potential gaps in the anti-corruption compliance program and accounting internal controls. We can provide audits and certifications of the anti-bribery management system under ISO-37001 and provide risk assessments and training regarding the anti-corruption compliance programs.
EXPERIENCE
- Brazilian chemical company’s worldwide operation investigating allegations of corruption in violation of the FCPA. Conducted a risked based data analysis of SAP transactional data to determine the scope of documents to review and analyze providing findings to the company’s Board of Directors.
- Brazilian chemical company’s operation in Mexico regarding allegations of corruption; Reviewed and analyzed third party invoices and supporting documentation and provided a report to management regarding findings.
- Venezuelan manufacturing client with an FCPA investigation into alleged illicit payments to foreign government officials in currency.
- American high-tech company’s Brazilian operations investigating allegations of fraud, corruption and conflicts of interest through two non-profit related entities in violation of the FCPA.
- American medical device company’s Brazilian operation investigating alleged payments by third party sales agents and distributors to doctors in violation of the FCPA.
- South American mining company in a civil action between an international mining company and several defendants regarding FCPA violations to secure mining rights in Africa.
- European based multi-national corporation in its investigation of alleged FCPA misconduct of one of its sales agents in the Middle East.
- Chinese high–tech company's American operations performing due diligence, training and compliance services regarding its Anti-Corruption and Anti-Bribery Compliance program.
- International financial services company conducting the first accredited ISO 37001 Certification audit and subsequent surveillance audits.
- Global software manufacturers FCPA risk based third party due diligence program.
Internal Fraud Investigations
We have conducted numerous internal investigations relating to occupational and employee fraud issues. Through fraudulent billing, payroll or expense reimbursement schemes we have assisted clients with the interviewing of employees and other related third parties in fact finding interviews to determine the depth these frauds have infected the organization. Our analysis of accounting, billing and other business records has provided a road map for our clients to address these issues across every level of the organization. In addition to investigation of employee misconduct, we also have expertise in reviewing clients’ compliance investigative processes as well as vendor management programs and on-boarding of third parties to ensure compliance with company’s objectives through due diligence and other public records research.
EXPERIENCE
- Country manager of a not-for-profit NGO funded by US Agency for International Development located in Nairobi, Kenya. The investigation included interviewing several members of the organization for vendor and procurement fraud over a five-year period.
- Country manager of a high-tech company’s operations in Argentina for misappropriation of Company assets.
- Chief Financial Officer in an internal whistle blower investigation of alleged accounting and securities fraud. This investigation included the analysis of company financial data and budgeting models, market forecasts and public filings and electronic document review.
- Chief Executive Officer and Chief Financial Officer for a publicly traded company for misuse of company funds for personal uses in an SEC investigation.
- Third-party vendor of a major pharmaceutical company investigating the receipt of illicit gifts, payments by company employees and third parties to include labor unions.
- Executives of a broadband services company conducting numerous interviews and administered financial analysis on several complex financial transactions used to improperly inflate the earnings through the recognition of income from dark fiber swaps and inflated earnings from its Video on Demand Service.
- Board members that were accepting bribe money and all-expense-paid trips to influence their decisions.
- Law firm employee who embezzled $2 million from various trust accounts tracing funds through several financial institutions resulting in forfeiture of assets.
- Employee of a third-party benefits payer for employee embezzlement and fraud; prepared report of findings and provided to law enforcement for prosecution; assisted client with enhancements to its internal control environment for fraud.