Foreign Corrupt Practices Act (FCPA) Case Studies
Baseline Compliance Reviews
AlixPartners conducted baseline reviews of FCPA compliance across multiple business units in more than 30 countries for a $40 billion multinational conglomerate. We performed investigations into potential violations and assisted with the company’s reporting of such reviews to the DOJ.
Due Diligence
AlixPartners provided FCPA due diligence on a strategic acquisition target in China, which was a top-tier private equity-backed company. When the entity was acquired, we assumed the interim compliance officer role to ensure a smooth and thorough transition. AlixPartners was involved in training, development and implementation of internal controls policies and procedures, transaction testing, and development of regional infrastructure to assume ongoing compliance.
Forensic Investigation
AlixPartners conducted a forensic investigation focusing on payments made on behalf of a publicly-traded, global, offshore, marine construction company by a freight forwarding agent to foreign government officials in Africa. We reviewed the company’s controls over its procurement and payment processes and assisted counsel when responding to information requests by the U.S. DOJ and SEC.
Independent Investigation
AlixPartners conducted an independent investigation into potential FCPA violations in various European countries on behalf of the Audit Committee of a European telecommunications company. We identified more than €30 million of inappropriate payments. We assisted in reporting the results of such reviews to U.S. regulators, including the DOJ, SEC and FBI.