Compliance

IGI brings strong capabilities to assist clients in compliance matters. Executive Vice President Larry Potts leads this practice area. His prior experience includes 15 years at the head of the compliance function of a prominent company in a highly regulated business.

Potts personally provides clients with practical C-Suite and Director level advice on a broad range of governance and management issues, including, for example: the role of directors and top management in an organization’s compliance culture; training and achieving cooperation of line managers in complying with thorny policy requirements; relationships with regulators; and staffing, training, and managing the organization’s internal monitoring and auditing function.

Potts’s comprehensive experience is also prominent in IGI’s capability to perform assessments of an organization’s compliance function. Annual independent assessments are widely considered to be a best practice and are required in various forms by many regulators. IGI also can assist in the development of comprehensive and practical policies and techniques to monitor and test adherence to those policies

IGI has substantial experience investigating suspected compliance issues, including, for example, bribes, defalcations, leaks of confidential information, and violations of AML and government contracting requirements. IGI’s extensive experience in vetting businesses and individuals around the world backs our due diligence work on vendors, partners, and agents- as required by the FCPA.

  • A U.S. financial services company with global operations retained IGI to provide investigative due diligence and consulting on internal controls in order to conform to Bank Secrecy Act and USA Patriot Act compliance requirements. IGI performed extended due diligence on a large book of foreign correspondent banking relationships the client was acquiring from another bank; our due diligence examined 220 banks in 35 foreign countries. Concurrently, we created on behalf of the client a proprietary suspicious financial transaction monitoring system to identify and flag potential money-laundering, tax evasion and terrorism financing-related transactions, which resulted in the discovery of billions of dollars in suspect transactions. On behalf of the client, IGI drafted Suspicious Activity Reports (SARs) and facilitated reporting to the relevant U.S. government agencies.
  • 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 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.