Case Study

Investigation uncovers FCPA and AML violations

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

After two previous investigations failed to provide evidence of any wrongdoing, a U.S. multinational company 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 Investigations analyzed 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.

Interestingly, a number of lower-level employees, who had not been interviewed in the course of the previous investigations, turned out to have knowledge of the suspicious activity while management continued to profess its ignorance. Stroz Friedberg Investigations led to the transfer or reassignment of a number of the subsidiary’s corporate officials.



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