Case Study

FCPA investigations – cross border privacy

Stroz Friedberg is a specialized risk management firm built to help clients solve the complex challenges prevalent in today’s digital, connected, and regulated business world

A billion dollar multinational company headquartered in the US with divisional headquarters in Paris, France was subject to an FCPA inquiry based on conduct that occurred in Asia. However, the key electronic data was located in the email boxes of French employees in France. As a result, the investigation had to adhere to French legalities. To comply with French labor law, we had to identify and remove any documents marked personal (or its equivalent) before the documents could be made available to the company’s legal team. Additionally, to comply with French data protection rules, the company’s French lawyers insisted that the data remain within France, and that the review be conducted under the supervision of a French Bailiff. We worked with the client, its outside counsel, and the French Bailiff to set up a review process in France to allow the company to comply with both its US and French legal obligations.

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