FCPA Investigations

IGI delivers sophisticated and specific expertise to supplement large law firms’ investigations into discrete incidents related to or entities involved in potential violations of the Foreign Corrupt Practices Act (FCPA). In addition, IGI regularly works for companies performing internal investigations on the practices of overseas subsidiaries, agents, and vendors. IGI gathers information on individuals and companies who may be conduits for corruption and provides clients with recommendations regarding remedial measures.

IGI helps clients identify potential violations – including how agents and third-parties may be creating potential exposure – and recommendations on steps to remedy issues and implement compliance measures.

With IGI’s timely support, clients can respond to and cooperate with regulatory bodies, reducing financial penalties and other adverse consequences.

IGI’s FCPA Investigations services include:

On-the-Ground Investigations

Every country in which IGI operates presents unique challenges. The availability of methods for accessing public records, data protection laws, and countless other factors can vary markedly from nation to nation. IGI’s network of investigators, sources, and affiliates affords clients the advantage of on-site investigators who not only develop the required information but also evaluate that information within the political, social, and economic context of a particular county – while always ensuring compliance with the laws of the jurisdiction in question, as well as the rules of professional responsibility and ethics.

Strategic Research and Analysis

IGI offers sophisticated investigative services conducted under the supervision of trained and experienced litigators. By gathering intelligence and providing strategic analysis of potential FCPA issues, IGI helps clients determine the best path forward. IGI’s FCPA investigative team includes forensic accountants, former intelligence analysts, senior law enforcement personnel, and former federal prosecutors with experience investigating and prosecuting international financial crimes and public integrity cases.

  • 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.
  • Our clients, officials of a foreign state-owned oil company, were accused in press reports in a major U.S. newspaper 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 documentary evidence including sworn witness affidavits that conclusively refuted the allegations and proved that the U.S. press reports were riddled with errors. Furthermore, IGI traced the false accusations back to a propaganda campaign by political opponents of the president of the foreign country who were working in tandem with political exiles living in the United States.