Bribery and Corruption
Independent and multi-disciplinary advice for organisations and external counsel on governance, enforcement actions and regulatory compliance.
Anti-bribery and corruption (ABAC) regulations have become increasingly complex in recent years, as international best practices evolve to keep pace with the changing landscape of cross-border coordination and cooperation between regulatory authorities. Though there are commonalities between regimes in different jurisdictions, such as the Foreign Corrupt Practices Act (FCPA), UK Bribery Act (UKBA) and Sapin II, there are also important nuances. These can have a critical impact on businesses to help mitigate their risks.
Whether entering a new market, enhancing compliance programmes or responding to regulatory action, we understand the challenges companies face. FRA's independent, integrated and tailored advice, built on decades of bribery and corruption experience, has helped hundreds of companies across the globe. Our highly skilled team draws on this expertise to advise our clients and their legal teams on mitigating inherent risks while still delivering the highest quality services to their clients.
Our Experience
Our Experience
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What our clients say
What our clients say
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What our clients say
What our clients say
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What our clients say
What our clients say
Client Reference
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What our clients say
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What our clients say
How we can help
Independent investigation support
We provide independent and robust response to serious allegations of internal and external misconduct including for whistleblower reports. Our extensive specialist experience helps clients navigate, and respond effectively and thoroughly to, regulatory subpoenas, informal requests, and investigations. We support external lawyers or internal teams in performing robust investigations, which stand up to the scrutiny of authorities around the world.
Risk assessment and mitigation
Whether targeted, holistic, or global, risk assessments are critical tools in identifying and helping to mitigate bribery and corruption risks. We have developed a bespoke compliance program framework, mapped against all leading international benchmarks and independently verified, to support the design or improvement of compliance programs.
Market-leading compliance monitorships support
FRA’s extensive experience enables us to support either the monitor or the company undergoing monitorship with the full range of forensic accounting skills and compliance expertise needed to demonstrate regulatory compliance.
Insights from Data & Technology
We use best-in-class technologies and specialists to provide early insights, navigate complex jurisdictional challenges and integrate seamlessly with our project teams.
Expertise
Internal Investigations
Helping international businesses navigate risks and emerge stronger from complex internal investigations.
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Helping international companies respond quickly and effectively to regulatory investigations.
More infoGovernance, Risk Management and Compliance Enhancement
Leaders in applying a forensic mindset to developing and enhancing corporate compliance programs.
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Exceptional, market-leading and trusted experts ensuring effective, proportionate and sustainable remediation.
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Multi-disciplinary expertise helping to anticipate and resolve a range of disputes.
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Solving your most challenging problems by integrating our extensive experience with advanced technology and bespoke solutions.
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Bespoke approach to evaluating a company’s key risks supporting a focused, proportionate and efficient action plan.
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Experienced collaborators with first-hand knowledge of how specialist forensic skills can best support the monitor’s role.
More infoControls Testing, Enhancement, and Implementation
Customized, rigorous testing to achieve internal controls effectiveness at the highest standards.
More infoAsset Tracing and Fund Flow Analysis
Experts in tracing misappropriated funds and identifying assets, helping to bolster legal positions and investigative strategy.
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Investigations
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Monitorships
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Disputes
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Advisory
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Data and Technology
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Integrated Data & Technology
We use best-in-class technologies and specialists to provide early insights, navigate complex jurisdictional challenges and integrate seamlessly with our project teams.
Integrated Data & Technology
We use best-in-class technologies and specialists to provide early insights, navigate complex jurisdictional challenges and integrate seamlessly with our project teams.
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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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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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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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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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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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Arbitration involving Bribery and Corruption
FRA was engaged by an arbitration panel to act as an independent party, to identify any corruption red flags associated with royalty payments.
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Petrofac
FRA was engaged by Petrofac and its external counsel to support the company’s plea discussions with the SFO, which had been investigating the company for several years in relation to bribery allegations contrary to the UK Bribery Act.
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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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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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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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