We were instructed by the Internal Auditor of a multinational power company to investigate alleged irregularities in a Middle East subsidiary. Interviews in-country with senior managers revealed they had diverted monies to create a slush fund to illegally pay $8m in kickbacks to acquire contracts worth $400m in breach of the US FCPA. Working closely with the client and its US lawyers, we prepared submissions to the US authorities that showed the extent of the fraud and how it was concealed.

As a result, our client was able to demonstrate it had acted swiftly and appropriately under the circumstances, thereby minimising its exposure to liabilities.