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Internal Investigation Resolves SEC Subpoena for Global Miner in Chile

A leading global mining company with operations in Chile had previously resolved corruption charges with U.S. regulators in 2017 related to improper payments to Chilean officials. When a whistleblower allegation prompted the Securities and Exchange Commission (“SEC”) to issue a new subpoena in 2023 regarding additional alleged improper payments to government officials, the company’s counsel engaged FTI Consulting to conduct an internal investigation. Our experts uncovered key intelligence demonstrating the company’s remediation efforts and helping counsel address and refute the allegations, ultimately leading the SEC to close the case.

Our Impact

The company’s legal team used visual stakeholder maps, thousands of data points and communications synthesized by our team to better understand the local political landscape and develop a fact-based legal strategy to assess and respond to the allegations.
Counsel gained critical evidence and context to address the allegations, helping demonstrate there was no evidence of improper activity and supporting a successful resolution.
The company avoided possible sanctions and significant disruption in operations, which would have otherwise severely impacted critical, high-value global supply chains.

Our Role

Our team of experts decoded and analyzed extensive WhatsApp conversations and email chains to uncover communications and transactions hidden with coded language.
FTI Consulting developed a comprehensive stakeholder map of politically exposed persons, influential third parties and other key actors, complemented by in-depth analysis of local Indigenous communities, their leadership structures and incentives that may have motivated certain third parties to engage in irregular or potentially fraudulent activity.
By conducting diligence on key subjects of interest and providing analysis on the regulatory and political landscape in Chile, our experts unearthed critical context for the actions of multiple actors identified during the investigation.