Leaders in designing, testing, and implementing compliance programs

5

of the top 15 FCPA settlements have involved our expertise

14

Compliance Monitorships involved with since 2009

30+

Countries in which we've conducted compliance reviews

We are leaders in designing, benchmarking, testing, and implementing compliance programs and risk assessments. Our bespoke approach is built upon our expertise in forensic accounting, eDiscovery and investigations.

Compliance reviews are at the core of our capabilities. We have conducted numerous corporate compliance reviews – both global and targeted – in over 30 countries. Our international team of experts have extensive experience of working in over 75 countries, as well as of approaches taken by regulatory authorities all over the world.

We have considerable experience assisting clients to develop robust compliance programs to address bribery and corruption, money laundering, sanctions abuse, general fraud, accounting fraud and misappropriation risks.

Our international team of experts have extensive experience in:

Pre-emptive assessments to identify potential compliance risk areas and enhancements to processes and controls;
Reactive reviews in instances where companies have identified or been alerted to areas of specific concern; and
Reviews for companies operating under Deferred Prosecution Agreement (DPA) compliance monitorships.

We have expertise in the following areas:

Our Bespoke Framework
Our Approach
International Standards
Industry Experience
Testing

Work With Us

Our Expertise

Tax Compliance (e.g. FATCA)
Sanctions and Trade Control (e.g. OFAC)
Human Rights
Corporate Social Responsibility (CSR)
Fraud and Detection and Prevention
Anti-Bribery and Corruption (ABC)

Data Transfer and Data Privacy
Product Liability
Anti-Money Laundering (AML)
Counter-Terrorism Financing (CTF)
Environmental

What Makes Us Different

Our Bespoke Framework

We have developed our own bespoke risk assessment framework, mapped against leading international benchmarks and independently verified, to support the design or improvement of compliance programs including third party due diligence procedures, internal financial controls and system effectiveness testing. Our expertise, combined with our in-depth knowledge of a client's operations and historical risk areas, is an effective way to ensure the most value is obtained from a compliance and internal controls review.

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Our Approach

Our approach can be adapted for companies needing to build up an end-to-end compliance program, to those requiring refinements or a bolt-on to an existing system.

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International Standards

Our benchmarking methodology has synthesized best practice from the widest possible range of international standards, aligning, in particular, with the expectations of the French Agence Française Anti-Corruption (AFA), the US Department of Justice (DOJ), the UK Serious Fraud Office (SFO) and others.

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Industry Experience

We have drawn on our deep experience from working closely with clients across a wide range of industry sectors and geographies to blend industry standard best practice into our approach.

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Testing

We test both Financial and Non-Financial Controls to provide a comprehensive assessment of the design and operating performance of compliance systems. Our approach considers risk areas from a top down and bottom up perspective.

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Bank Leumi

AML and Sanctions, Compliance and Risk Assessment, Corporate Compliance Monitorships

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. Post-settlement, FRA served

International Mining Company

Compliance and Risk Assessment, Investigations

FRA was initially instructed by a UK-listed mining company with interests in Africa, the CIS and Latin America, to carry out a review for compliance with the UK Bribery Act. When the company found itself under investigation by the UK Serious Fraud Office (SFO), our assignment expanded into a detailed review of transact

The Sedona Conference Commentary on Ephemeral Messaging

Ephemeral messaging is an increasingly popular communication option for organizations and their employees around the globe, offering organizations a robust option to strengthen aspects of their corporate information governance programs by enabling secure communications and facilitating compliance with data protection and privacy laws. Despite its growing use, there are concerns about its widespread adoption. Government […]

French environmental law, deferred prosecution agreements (CJIP), and the imperative for compliance programs

What impact will the Environmental CJIP have on French companies’ compliance programs? This article was first published in French in Le Journal du Management juridique et réglementaire d’entreprises. In 2017, the Sapin II law1 introduced in the French legal system the possibility to resort to a settlement called the “Convention judiciaire d’intérêt public” (“CJIP”), for […]