The audit committee of a multinational manufacturer with operations spanning North America, Europe, and Southeast Asia received an anonymous whistleblower complaint. The complaint alleged that a procurement official at one of the company's international subsidiaries had directed contract awards to favored vendors in exchange for undisclosed personal benefits. Preliminary review by internal compliance staff suggested the allegations were credible and potentially involved multiple individuals and jurisdictions. The audit committee determined that an independent external investigation was required before any decision on voluntary disclosure or regulatory response could responsibly be made.
Law & Forensics was retained by outside counsel to the audit committee to conduct the investigation.
The Challenge
FCPA and anti-corruption investigations at multinationals present compounding complexities. Evidence is distributed across jurisdictions with different data protection regimes, employment laws, and legal privilege frameworks. Financial flows are often deliberately obscured through layered intermediary entities, nominee vendors, and informal payment channels. Witness interviews must be conducted in ways that are both legally compliant across jurisdictions and strategically calibrated given the possibility of regulatory scrutiny.
The audit committee required findings that would be defensible not only internally but to any regulator that might later review the company's response to the allegations.
What Law & Forensics Did
Law & Forensics organized the investigation around three integrated workstreams, conducted under the protection of attorney-client privilege directed by outside counsel.
Financial Forensics. The team performed a forensic analysis of procurement transactions at the relevant subsidiary over a multi-year look-back period. Using advanced analytics, the team identified statistical anomalies in vendor selection, pricing, and payment patterns—patterns inconsistent with arm's-length procurement. Financial flows were traced through subsidiary ledgers, third-party intermediary structures, and available banking records to document the movement of funds to potentially improper recipients.
Digital Evidence Review. Law & Forensics collected and forensically processed email, enterprise messaging, and financial system records from relevant custodians. Targeted review using technology-assisted review workflows identified communications bearing on the allegations—including internal discussions of vendor relationships, approvals, and benefit transfers that would not ordinarily appear in financial records alone.
Witness Interviews. Working with outside counsel, the team supported structured interviews of key witnesses, using forensic findings to develop informed questioning strategies. The combination of documentary evidence and interview testimony produced a corroborated factual record.
Outcome
The investigation produced a comprehensive written report to the audit committee documenting the factual findings, evidentiary basis, and identified compliance program gaps. The report provided the company's counsel with the information needed to make a well-grounded decision about voluntary disclosure and remediation. Targeted compliance program enhancements were recommended and prioritized.
The engagement reflects Law & Forensics' full-service investigative capability: the ability to combine former-enforcement professional judgment, forensic accounting rigor, and digital evidence expertise into a single, defensible investigation.
Related Practice Area
Investigations Services — Anti-Bribery, AML, and Corruption; Forensic Accounting and Fraud; Whistleblower Allegations; Financial Regulatory Enforcement and Compliance Response
