Case Study

FCPA investigations – Rogue Subsidiaries

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

Stroz Friedberg assists a multinational corporation with FCPA investigations, unveiling money laundering and FCPA violations of one of its rogue subsidiaries.

After two previous investigations failed to provide evidence of any wrongdoing, a U.S. multinational client continued to be suspicious of misconduct in its Geneva-based subsidiary. A Stroz Friedberg Investigator was called to conduct and manage a global investigation of suspected violations of the Foreign Corrupt Practices Act (FCPA), money laundering and improper trading practices by the “rogue” subsidiary. Stroz Friedberg spent seven months analyzing approximately $9 billion in transactions, including the manual review of wire transfers, and interviewing witnesses in Europe and the Middle East. The investigation uncovered a number of “highly suspect” third-party payments and receipts— a classic indication of money-laundering practices, and evidence of violations of US and UN sanctions (“Trading with the Enemy”).



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