Case Studies

Anti-Corruption Due Diligence & Investigations

  • On behalf of a firm in the construction industry, IGI has conducted multiple FCPA-focused due diligence investigations on potential joint venture partners, clients and vendors located overseas.  In these matters, we supplemented online and on-site public records and database research with in-country interviews and human intelligence gathering to provide best-practices FCPA compliance and business due diligence processes to search for “red flags” from regulatory, reputational and legal standpoints.  Our work for this client has included due diligence investigations of entities and individuals based in Eastern Europe, Central America, and the United Kingdom.
  • A major U.S. energy company considering an acquisition of exploration rights in West Africa from a European independent asked IGI to assist in assessing the possibility of FCPA taint on the assets. IGI’s research in Europe, West Africa and the United States included histories and profiles of the selling company and its current and former executives, relevant officials of the West African countries, and previous transactions involving the exploration rights.
  • Officials of a foreign stated-owned company were accused of accepting millions of dollars of bribes and kickbacks from purported agents and intermediaries outside the company. IGI performed an internal investigation in the foreign country, located and interviewed the purported agents and intermediaries in the foreign country and in the United States, and gathered evidence including sworn witness affidavits that refuted the allegations. Furthermore, IGI traced the false accusations to a propaganda campaign by political opponents of the head of the foreign government.
  • A U.S. bank with embassy and foreign government banking business was embroiled in a scandal related to money laundering for heads of state and officials of foreign governments. At the time IGI was brought into the case, U.S. government agencies and the bank’s auditors had already conducted investigations. IGI was retained by the bank’s outside counsel to independently review the scope of the findings of the previous probes and to identify and investigate additional concerns.
  • IGI compiled evidence that local agents working on behalf of a Western company bidding on a large construction project in an Asian country had paid and promised bribes to government officials who were to award the contract. IGI also developed evidence that a principal of another company, which had won major infrastructure contracts in the same Asian country, was involved in multimillion-dollar business and real estate deals in the U.S. with members of the Prime Minister’s family.
  • A Dubai-based commercial bank hired IGI to conduct an internal probe after the bank’s risk managers received reports from scores of customers complaining of unauthorized ATM withdrawals from their accounts. IGI debriefed the bank’s risk managers, interviewed bank employees and customers, viewed bank surveillance tapes and reviewed ATM transaction records. We collected evidence and secured the confession of a senior bank manager to uncover and identify the perpetrators of a sophisticated international identity theft ring, ATM card counterfeiting and money laundering ring that spanned Europe, the Middle East and Southeast Asia.
  • A Central American financial institution retained IGI’s forensic accountants and investigators to conduct a comprehensive review of its operations as it prepared to enter the U.S. market.
  • IGI’s experience in investigation foreign corruption matters dates back more than 30 years to when Terry Lenzner, IGI’s Chairman, uncovered a series of bribe payments in Chile and other countries involving General Tire and Rubber Co. that ultimately led to the Federal Communications Commission revoking multiple television licenses held by RKO-General, a subsidiary of General Tire and Rubber Co.