Forensic Investigation – Foreign Corrupt Practices Act
Client: Telecommunications Equipment Provider
Project: Forensic Investigation – Foreign Corrupt Practices Act
A large multi-national telecommunications company was the subject of an investigation for potential violations of the Foreign Corrupt Practices Act. The ESI team conducted an international independent forensic investigation in three continents that reviewed accounting methodology and ESI.
The independent accounting team was tasked with concluding if any evidence of bribery of foreign officials existed. Teams of computer forensics and forensic accounting professionals were deployed in North America, Europe, and Asia. Documents and data in foreign languages were processed and analyzed. Collections were performed in California, Italy, Thailand, Taiwan, and Korea. The time frame with respect to the completion of the investigation was limited, inasmuch as the company risked being de-listed from NASDAQ, in the event that the investigation was not adequate or timely. Adhering to the privacy restriction protocols of international jurisdictions was also an obstacle during the course of the work performed.
Working closely with attorneys and forensic accountants, the team collected, processed, analyzed, and reviewed ESI from around the world. Review platforms were organized for international reviewers to evaluate potentially relevant ESI. The team worked with local counsel to conform to local privacy protocol.
- Forensic collections in international locations
- Processing and loading of ESI to assess environments for international review
- Authored reports as an E discovery expert on:
- The procedures used for electronic discovery
- Detailing violations of the preservation orders
Evidence identified allowed the company to report improprieties to the SEC and correct issues with employees who were found in violation of corporate policy.