Anti-Corruption Investigations & Compliance
The FTI Consulting Anti-Corruption Investigations & Compliance team provides leading global capabilities to help companies mitigate corruption risk and investigate and prevent corruption issues. Our specialists advise corporate officers (General Counsel, Chief Compliance Officers), corporate board directors, white-collar defense attorneys and government appointed monitors, and help our clients address corruption risks and respond to multi-jurisdictional matters arising from alleged violations of the Foreign Corrupt Practices Act (“FCPA”), the UK Bribery Act (“UKBA”), Brazil’s Clean Company Act and other related global statutes. Our services fall into three broad categories: corruption risk mitigation; investigation of allegations; and assistance with remediation.
Our Service Offerings
We help our clients conduct proactive corruption risk assessments, enhance compliance programs and perform value-added analysis that help decision-makers address and mitigate specific corruption risks.
Our multidisciplinary team:
- Conducts corruption risk assessments including pre-acquisition corruption risk reviews
- Designs and implements risk-based compliance programs
- Performs geopolitical risk assessments and market entry analysis
- Conducts integrity investigations of pre-acquisition targets, agents, resellers and other third parties, including politically-exposed-persons (PEPs)
- Offers FTI COMPLY, an online compliance tool to organize, monitor and centrally manage third-party due diligence
- Performs post-acquisition and third-party compliance audits
- Trains employees on corporate anti-corruption policies and corporate governance officers on incident response protocols
We offer a wide range of expert support at every stage of a global corruption investigation.
- Perform forensic accounting tests of business transactions
- Collect information through publicly available material, conduct interviews and investigate beneficial relationships
- Identify and preserve electronic data and hard copy records
- Analyze data and uncover relevant documents and information using advanced analytics applied to unstructured data and state-of-the-art tools to analyze structured data sets
- Reconstruct accounting records
- Combine output with information and evidence gathered elsewhere to establish the fact pattern
- Produce a report for key stakeholders based on our investigation that answers the questions who, what, where, when, how and why
- Identify control weaknesses and potential gaps in the anti-corruption compliance program and accounting internal controls
- Provide information to assist outside counsel on the appropriate case strategy
- Create a crisis communications strategy and tactical implementation plan
Concurrent with, or following, a corruption investigation, our integrated teams of professionals are experienced in assisting our clients with reporting to key stakeholders and regulators, and developing and implementing remedial plans designed to enhance anti-corruption protocols and internal accounting controls.
Our integrated teams can assist with:
- Quantifying the proceeds of corruption for disgorgement and recovery purposes
- Calculating the company’s ability to pay fines to support legal counsel in negotiations with regulators
- Acting as an independent compliance consultant reporting to the Board
- Assisting a court-appointed monitor pursuant to a settlement agreement or prosecution
- Developing and implementing remediation plans to address control weaknesses in a particular business or systemic issues across the anti-corruption compliance program
- Developing or modifying anti-corruption policies and procedures
Senior Managing Director, Co-Leader of Forensic Accounting & Advisory Services