Bank Leumi
FRA was engaged to support the monitorship of an Israeli bank and its subsidiaries, who between 2000 and 2011 were found to have wilfully assisted US clients in opening and maintaining undeclared accounts in a foreign country, and concealing offshore assets and income from authorities.
Challenge
FRA was engaged to support the monitorship of an Israeli bank and its subsidiaries, who between 2000 and 2011 were found to have willfully assisted US clients in opening and maintaining undeclared accounts in a foreign country, and concealing offshore assets and income from authorities. Post-settlement, FRA served as the forensic consultant to the appointed independent compliance monitor under the terms of a Consent Order. The monitorship involved conducting a comprehensive evaluation of the bank’s global compliance function.
Action
FRA designed and executed compliance-focused data analysis and testing of relevant aspects of the bank’s compliance program, as related to US Department of Treasury’s Office of Foreign Assets Control (OFAC), US Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) and the Foreign Account Tax Compliance Act (FATCA), and assisted in the assessment of the bank’s corporate governance across multiple jurisdictions. The assessment included interviews with key members of the compliance and AML teams, evaluation of the Know-Your-Customer (KYC) program, Enhanced Due Diligence procedures, customer risk rating systems, and transaction monitoring and reporting systems. FRA’s analysis and testing of data from multiple disparate bank systems was performed under strict data privacy and security protocols agreed with the bank.
Solution
FRA’s analysis enabled the monitorship team to develop a series of practical and realistic recommendations — at both the global and local level — for the bank to implement in support of strengthening its global compliance program.
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Gunvor SA
The Geneva-based independent commodities trading house has agreed to pay more than $660mn to resolve corruption investigations by Swiss and US authorities. Gunvor engaged two teams of FRA experts to test and evaluate its compliance program, and to support the fine calculation as part of negotiations with the DOJ.
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Entain
FRA supports Entain's £585 million groundbreaking settlement with Crown Prosecution Service.
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Pro Bono Anti-Fraud Training for the IFRC
Members of our forensic accounting and data analytics teams delivered quarterly virtual training sessions for staff in relevant roles across the 192 National Societies of the International Federation of the Red Cross and Red Crescent Societies (IFRC).
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ABB
In December 2022, the Switzerland-based multinational technology company reached a “full and final settlement” of $327 million with several national authorities. A multi-disciplinary, international team of FRA specialists supported the company through their cooperation with the authorities over more than three years, from investigation to settlement to compliance remediation.
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Airbus
FRA advised Airbus and its counsel from the early stages in designing a robust and forensically based approach to the investigation, customising a data governance strategy alongside compliance risk assessment and remediation support, as well as the eventual fine calculation.
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NFT Marketplace Controls
As Head of Regulatory Affairs at a well-known gaming company, an FRA partner led the development of AML and Fraud controls to protect the company's Non-Fungible Token (NFT) Marketplace.
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High Court Claim related to Oil & Gas Services Company
Our client was defending a multi-billion dollar High Court claim in relation to alleged breaches of a long-term logistics contract. FRA was engaged to provide expert witness support and evidence in relation to the calculation of potential damages associated with loss of profits.
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APT Group Cryptocurrency Money Laundering
Reacting to cyber attacks by an Advanced Persistent Threat (APT) group on critical US infrastructure, an FRA Director conducted thorough and sophisticated cryptocurrency asset tracing to identify and disrupt the group's activities.
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European Bank
A European bank approached FRA to perform an initial evaluation of its exposure related to customers allegedly involved in money laundering activities. This was of concern to the client given the potential regulatory, financial and reputational implications for the bank.
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Nordic Telecommunications Company
FRA was instructed by Telia Company (market cap: over $17 billion) and its counsel in the UK, US, the Nordics and Holland to provide forensic accounting and eDiscovery consulting services in the investigation of the Scandinavian telecoms company.
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Cryptocurrency Terrorism Financing
An FRA expert provided critical support to the FBI's Counterterrorism Division, in connection with a multi-agency task force uncovering cryptocurrency terrorist financing. Their efforts led to the most significant US seizure of cryptocurrency to date.
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Expert Witness to the Quebec Superior Court
FRA provided pro-bono support to a Canadian individual who brought a case to the Quebec Superior Court to challenge the Canadian Criminal Code law that allows police officers to make traffic stops without suspecting any offence being committed.
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Cryptocurrency Exchange Collapse Due to Fraud
FRA was retained by external Counsel to represent multiple clients under investigation by the Southern District of New York (SDNY) in connection with the downfall of a prominent cryptocurrency exchange.
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Responding to a Data Subject Access Request (DSAR)
FRA supported a client's response to an ex-employee's Data Subject Access Request (DSAR) with a limited time period to respond. FRA applied a DSAR solution to gain a holistic view of more than 900,000 documents, eliminate redundancies; redact confidential information, and deliver a complete and structured response.
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International Not-for-Profit Organization
FRA was approached to provide pro bono support to a not-for-profit organization that had identified potential anomalies in its accounting and banking records.
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Middle-East Telecommunications Company
FRA was retained to support one of the world’s largest mobile telecommunications companies in an internal investigation which required an eDiscovery review in the context of alleged compliance violations.
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Multinational Oil and Gas Extraction Company
FRA was retained by counsel to assist a client performing a due diligence exercise in connection with purchasing an oil and gas producer in West Africa.
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Cryptocurrency Exchange FCC Review
FRA assisted a major cryptocurrency organization to address the financial crime regulator's concerns about their Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF) and Sanctions compliance.
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Multinational Life Sciences Company
FRA was retained by US counsel to assist a life sciences firm assigned under a Deferred Prosecution Agreement (DPA) related to violations of the US Foreign Corrupt Practices Act.
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Illicit Online Marketplace
An FRA Director led an investigation into a nefarious online marketplace, applying complex data analysis resulting in the arrest of numerous cybercriminals selling illicit goods and services.
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International Event and Talent Management Company
An employee of an international talent agency left the company and took with them several high-profile clients to a direct competitor.
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Cryptocurrency Exchange Collusion
When a new cryptocurrency experienced sudden delisting from multiple exchanges, their Counsel urgently engaged an FRA partner to help investigate potential antitrust or collusive behavior.
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Rolls-Royce
Rolls-Royce plc, the UK-based manufacturer and distributor of power systems for the aerospace, defense, marine and energy sectors, was under investigation by the US Department of Justice (DOJ), UK Serious Fraud Office (SFO) and Brazilian authorities in relation to an alleged long-running scheme to bribe government
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Sanctions and the Russia-Ukraine War
An FRA expert was responsible for monitoring and investigating cryptocurrency sanctions exposure originating from the Russia-Ukraine war to protect customers from sanctions violations.
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Multinational Insurance Firm
FRA was retained by a major European-headquartered insurer (market cap: over $60 billion) involved in a legal dispute with a US client. The US-based litigation required a potentially wide-ranging and costly eDiscovery exercise.
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Multinational Transport Engineering Company
FRA was retained by US counsel to Alstom (market cap: over $10 billion) to assist with defending a US securities class action suit. The case involved allegations around export credit financing of a division that Alstom had sold to a third party.
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Class-action Lawsuit challenging Solitary Confinement in US Prisons
FRA was approached by our client, White & Case, to provide pro bono support to the ACLU in their federal class-action lawsuit seeking to end solitary confinement in two Virginia prisons.
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Holocaust Restitution Claims Administration
FRA was retained separately by Swiss and German authorities to build claims administration systems for hundreds of thousands of holocaust survivors, facilitating the disbursement of hundreds of millions of dollars over five years. These were among firm's first engagements after our founding at the turn of the century.
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UN Oil for Food Program
As part of a UN investigation into possible corruption in the Iraqi Oil-for-Food program, FRA carried out a forensic accounting review and eDiscovery exercise.
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Technip
Following the imposition of a monitor in a joint resolution by the US Department of Justice (DOJ) and US Securities & Exchange Commission (SEC), Technip retained FRA to review the company’s anti-bribery measures and export control compliance program, provide forensic accounting and eDiscovery services and train the client’s internal audit staff to autonomously conduct future internal reviews.
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