Situation
A multinational organization required investigation into potential violations of the Foreign Corrupt Practices Act across several international operations, raising concerns around improper payments and books-and-records compliance.
SFG Role
SFG led multiple cross-border FCPA investigations, assessing compliance risks and identifying potential misconduct across key jurisdictions.
Approach
- Conducted investigations across Latin America, India, Italy, and Spain
- Performed analytical procedures to identify irregular transactions and risk indicators
- Reviewed financial records and supporting documentation for compliance gaps
- Conducted information-seeking interviews with relevant personnel
- Identified potential books-and-records violations and indicators of improper payments to government officials
- Developed findings and actionable recommendations to mitigate compliance risks
Outcome
The investigations uncovered control deficiencies and potential compliance breaches, enabling the client to take corrective action, strengthen internal controls, and reduce exposure to regulatory enforcement.