Anti-Corruption & Compliance
Effective anti-corruption work begins well before an investigation is necessary.
Doing business in the global marketplace presents a multitude of financial and operational challenges and can expose companies to a variety of risks including bribery and corruption activity. Companies that run in conflict of the Foreign Corrupt Practices Act and of other similar laws in foreign jurisdictions face challenging and potentially costly impacts on their business. Our professionals have assisted several clients with reactive anti-corruption investigations and proactive compliance matters.
Our professionals assist clients in defending against government enforcement inquiries. We have significant expertise with high-profile and high-stakes government enforcement matters.
Bribery & Corruption Investigations
Our forensic consultants investigate allegations under the FCPA, UK Bribery Act, and applicable local statutes. Every finding is grounded in evidence and every methodology documented, because the regulators and counsel reviewing our work will examine both.
Monitor Support
Where a court or regulator requires independent oversight, Gemean takes on the monitor role, conducting required reviews, producing objective findings, and reporting with the independence that makes the process credible to all parties.
Pre-Acquisition Due Diligence
Corruption risk acquired through a transaction becomes the acquiring organization's problem. Our forensic accountant consultants assess target companies for bribery exposure, control deficiencies, and undisclosed liabilities before the deal closes.
Risk Assessments
We evaluate corruption risk across geographies, third-party relationships, and business units, providing a clear, evidence-based view of where exposure is concentrated and what requires priority attention.
Internal Controls Assessment And Remediation
We identify deficiencies in existing compliance programs, assess their practical significance, and work with organizations to implement controls that function as intended and not just on paper.
TESTIMONIAL
Gemean understood the legal context as well as the forensic one. They knew what the regulators would focus on, what outside counsel needed, and how to structure the findings to serve both. That combination is not easy to find.
Scrutiny-Proof Findings
Multi-Jurisdictional Experience
Rapid Engagement
Seamless Integration
The earlier expert support is engaged,
the more it can influence
What is the Foreign Corrupt Practices Act and who does it apply to?
The FCPA is a US federal law that prohibits companies and individuals from bribing foreign government officials to obtain or retain business. It applies to US companies and citizens operating anywhere in the world, as well as foreign companies listed on US stock exchanges. The extraterritorial reach of the FCPA is broad, and many organizations are subject to it without fully realizing it.
What is the difference between a reactive investigation and a proactive compliance review?
A reactive investigation is triggered by an allegation, a whistleblower report, or a government inquiry. A proactive compliance review is conducted before something goes wrong, with the goal of identifying risk and closing gaps before they become enforcement matters. Both require the same rigor, but the timeline and stakes are very different.
How do Gemean's forensic accounting consultants approach a bribery investigation?
Every investigation begins with scoping and evidence preservation. From there, our forensic consultants collect and analyze financial records, communications, and transactional data relevant to the allegation. Findings are documented methodically and structured for use by legal counsel, audit committees, and regulators. The goal is always a defensible, evidence-backed result.
What does an independent monitor do?
An independent monitor is a neutral third party appointed by a court or regulator to oversee an organization’s compliance with a settlement agreement or consent decree. The monitor conducts periodic reviews, reports findings to the relevant authority, and verifies that required changes are being implemented. Gemean takes on monitor roles across a range of enforcement contexts.
Why is pre-acquisition due diligence important for anti-corruption purposes?
Corruption risk does not disappear when a transaction closes. If a target company has engaged in bribery or has deficient controls, the acquiring organization can inherit that liability. A thorough pre-acquisition forensic accounting investigation identifies those risks before they transfer, giving leadership the information needed to negotiate, remediate, or walk away.
How quickly can Gemean mobilize for an urgent matter?
Our forensic consultants are structured to begin an engagement within 24 hours. For organizations facing an active government inquiry or a time-sensitive internal situation, early engagement is one of the most important factors in how the matter develops.
Does Gemean work with outside legal counsel?
Yes. We operate under the direction of outside counsel on the majority of our engagements. Our role is to provide the forensic accounting and investigative expertise that supports the legal strategy, not to duplicate it.