Experts on many of the world's largest compliance matters

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 regularly hired by law firms and corporations to provide expertise on some of the world's largest compliance matters and are consistently recommended for our ability to go the extra mile. Our diverse team are experienced in conducting internal and regulatory investigations, performing and evaluating transactional and controls testing, and undertaking reviews of compliance programs in a wide variety of contexts.

We have served as an independent monitor and also supported monitors appointed by the US Department of Justice (DOJ), US Securities & Exchange Commission (SEC), Public Company Accounting Oversight Board (PCAOB) and New York Department of Financial Services (NYDFS) on a number of matters. We have been involved in monitorships related to Anti-Bribery and Corruption (ABC), Anti-Money Laundering (AML), Office of Foreign Assets Control (OFAC) sanctions violations, fraud, and PCAOB accounting and auditing standards.

We have also assisted clients operating under Deferred Prosecution Agreements (DPAs) in preparing for and interacting with compliance monitors. In this capacity, we have been responsible for the assessment, design and/or monitoring of compliance policies and procedures.

We combine the latest data mining technology with forensic investigative accounting expertise to assist companies and their legal counsel in a broad range of areas including corporate and social responsibility, human rights, product liability, sanctions, anti-bribery and corruption, anti-money laundering and terror financing, and taxation.

We have expertise in the following areas:

Understanding Regulators
Compliance Analytics
Forensic Investigation Expertise
Experts in Complex Calculations

Work With Us

Our Services

Review, revision or drafting of policies and procedures.
Assessment of existing internal controls through walkthrough evaluations.
Testing of existing compliance and financial controls through detailed transaction testing.

Redesign of existing controls or development of additional compliance/financial controls to enhance a compliance program.
Development of training materials to ensure the purpose and execution of controls is understood by individuals responsible for their completion.

What Makes Us Different

Understanding Regulators

We have considerable experience interacting effectively with regulators around the world. Our teams have presented before regulators in connection with internal investigation findings and reporting as a Monitor or part of a monitorship team. Combined with the advantage of having former regulators on our team, we have deep insight into regulators’ expectations and requirements and how companies should best communicate to them.

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Compliance Analytics

Our monitorship approach utilizes data analytics to provide rigorous and tailored testing of existing and newly implemented controls to assess their effectiveness with the ultimate goal of providing recommendations and practical solutions to align governance and internal controls. We collect and analyze data for use in legal disputes and investigations in a number of areas, including litigation, fraud, bribery and corruption investigations.

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Forensic Investigation Expertise

We have considerable experience in investigating and remediating allegations of accounting and disclosure fraud, money laundering, trade control violations and sanctions, corruption and bribery, and asset misappropriation and embezzlement. We offer seamless integration across our service areas and subject matter experts to help clients build robust and customized compliance programs.

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Experts in Complex Calculations

We have been engaged in a number of high profile settlement discussions, including disgorgement penalties and ability to pay calculations, which can sometimes accompany a monitorship or deferred prosecution agreement (DPA). We have presented in connection with financial settlements with the US DOJ, SEC, OFAC and UK SFO as well as Swiss, French, Dutch, Swedish and Brazilian authorities. We understand what approaches regulators and enforcement authorities will accept and/or have accepted in the past.

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Technip

Corporate Compliance Monitorships, Investigations

In 2010, Technip was facing charges under the US Foreign Corrupt Practices Act (FCPA) for its alleged participation in a decade-long scheme to bribe Nigerian government officials to obtain engineering, procurement and construction (EPC) contracts. The EPC contracts to build liquefied natural gas (LNG) facilities on Bon

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

GIR Guide to Monitorships: Leveraging Forensic Accountants

During the past decade, the use of monitorships has matured considerably, with an increasing number of regulators and enforcement entities implementing this form of remediation. Jurisdictions outside the United States have moved beyond nurturing an interest in monitorships to formally legislating their application in settlement negotiations. It was once more common for monitorships to stem […]

The New DOJ Antitrust Procurement Strike Force

On November 5, the Department of Justice (DOJ) Antitrust Division announced a new Procurement Collusion Strike Force (PCSF). The PCSF aims to deter, detect, investigate, and prosecute antitrust crimes and related criminal schemes that undermine the integrity of the government procurement process. Interagency partnership will consist of prosecutors from DOJ’s Antitrust Division plus 13 US […]