Case Examples

Investigation on behalf of a Manufacturer (Europe):

Investigated allegations of related party transactions, expense reimbursement fraud, and violations of the Subject company's code of conduct. Conducted interviews, analyzed expenses comparing written policies, and reviewed email and instant messaging records.

Result: Uncovered related party ownership information of vendors located in Europe. Identified several violations of the Client's code of conduct and expense reimbursement policies.

Financial Due Diligence on behalf of a Private Equity Investor:

Provided financial due diligence on a lender (possible acquisition), a global marketing company. Conducted interviews, reviewed the existing ABAC policies, code of conduct, and employee handbook, reviewed litigation expenses and conducted limited background checks on key employees.

Result: Discovered that although they had a large international law firm conduct third-party due diligence on an agent, the red flags of historical fraud were ignored. The litigation expenses were significant since they were being sued/accused of being a pyramid scheme.

Internal Fraud Investigation on behalf of a Manufacturer (Mexico):

Investigated allegations of embezzlement by a controller in Mexico. Interviewed employees, and analyzed accounting records including vendor payments, vendor invoices, and shipping documents. Vendors who were identified as related parties were visited and determined that these vendors could not have provided these services based on documentation and discussion with them.

Result: Discovered that the Controller set up false vendors (or related party vendors) and had client pay vendors for services not rendered. Controller had access to creation of vendors, payment of vendors and had, in fact, embezzled!

Based on our recommendations, this investigation was followed by an internal control review from purchase order to payment with internal audit director. Also, subsequently conducted a fraud risk assessment for a US affiliate involving interviewing employees, reviewing policies and procedures and providing a report.

Development of Compliance Program on behalf of an Engineering Consulting Company:

Created an anti-bribery/anti-corruption ("ABAC") compliance program. Conducted interviews of key employees and wrote ABAC policies, code of conduct and employee handbook. Wrote procedures for ABAC internal controls: International Expense reimbursement, Third-party prioritization and vetting/due diligence, Internal Disbursements, Authorization process, Ethics hotline review, and investigations.

Result: The ABAC program development was followed by conducting the ABAC training and performing FCPA due diligence for the company.