Investigations / Compliance Consulting

Anti-Bribery & Anti-Corruption (ABC)

J.S. Held’s Inaugural Global Risk Report Examines Potential Business Risks & Opportunities in 2024

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Our experts assist clients in developing, testing, and strengthening compliance programs and responding to government investigations and enforcement actions under the U.S. Foreign Corrupt Practices Act (FCPA), U.K. Bribery Act, and other global anti-bribery laws and regulations.

Our experts provide a wide range of proactive, reactive, and remedial anti-bribery and anti-corruption services. We utilize a risk-based testing approach to help clients enhance existing compliance programs. We deliver expertise in anti-bribery and anti-corruption program assessments; internal controls review; enhanced due diligence of third-party vendors, agents, and intermediaries; due diligence in mergers and acquisitions; cross-border investigations; and monitorship support.

Our Proactive Services
  • Anti-Bribery & Corruption Policies & Procedures Review
  • Compliance Program Assessment
  • Compliance Program Gap Analysis
  • Data Analytics & Continuous Monitoring Systems
  • Employee Training
  • Internal Audit ABC Planning & Testing Assessment
  • Internal Control Assessment
  • Risk Assessment
  • Third-Party Due Diligence
  • Transactional Intelligence & Due Diligence
Our Reactive Services
  • Ability to Pay Analysis
  • Evidence Collection, Preservation & Analysis
  • Forensic Accounting Review of Financial & Operational Data
  • Government Investigations & Inquiries Support
  • Internal Control Remediation & Program Redesign
  • Monitorship Assistance
  • Transaction Testing
  • Reconstruction of Accounting Records
  • Internal Investigations
Our Subject Matter Experts
  • Certified Public Accountants (CPA)
  • Certified Fraud Examiners (CFE)
  • Certified in Financial Forensics (CFF)
  • Chartered Global Management Accountant (CGMA)
  • Certified Forensic Computer Examiners (CFCE)
  • Certified Information Systems Security Professionals (CISSP)
  • Computer Forensic Specialists (EnCase Certified Examiners)
  • Data Analysts
  • eDiscovery Specialists
  • FCPA Experts
  • Forensic Accountants
  • Former Corporate Internal Auditors
  • Former Law Enforcement Agents
  • Former Prosecutors
  • Political Risk Consultants
Clients & Industries Served

We serve boards of directors, audit committees, executive management, compliance officers, and in-house legal professionals of multinational corporations around the globe. With extensive knowledge and experience, we serve clients across various industries, including:

  • Agriculture
  • Construction
  • Consumer Products & Services
  • Financial Services
  • Healthcare / Life Science / Medical Device
  • Hospitality
  • Industrial/Manufacturing
  • Insurance
  • Energy/Oil, Gas & Utilities
  • Real Estate
  • Technology, Media & Telecommunications
  • Transportation Infrastructure
Proactive Services

In a climate of continued focus on regulation and enforcement, our multidisciplinary team provides comprehensive, proactive corruption risk mitigation services that are tailored to our clients’ needs. We have a deep understanding of anti-bribery and anti-corruption requirements around the world, including the U.S. FCPA and the U.K. Bribery Act. Our services include evaluation of compliance programs, policies, and procedures, including transaction testing to assess whether policies and procedures are adhered to day-to-day; review and testing of internal controls for operating effectiveness; ongoing screening, monitoring, and enhanced third-party due diligence; compliance monitoring; and employee training.

Utilizing a risk-based approach, we combine data-driven risk mapping with qualitative and quantitative factors to help clients prevent and detect potential risk areas. Through ongoing testing and evaluation of compliance programs, we help our clients meet and maintain compliance standards in numerous jurisdictions and help to anticipate emerging bribery and corruption risks.

Reactive Services & Remediation

We are retained to perform investigations stemming from whistleblower allegations, regulatory inquiries, and other concerns raised by boards of directors, organizations, and their counsel, often in connection with civil or criminal matters. Our experts in forensic accounting, forensic technology, and business intelligence leverage extensive knowledge and understanding of the laws and regulations in jurisdictions throughout the world to assist counsel in corporate internal investigations. We assist clients in matters involving the FCPA Corporate Enforcement Policy and Department of Justice (DOJ) inquiries. We also deliver strategic guidance regarding interaction with outside auditors in Securities & Exchange Commission (SEC) filings.

Throughout an investigation, our experts conduct interviews with witnesses; collect, analyze, and preserve electronic data; and examine financial records, compliance programs, and internal controls to deliver independent, unbiased reports on our findings. In government investigations, we help clients to determine the root cause of the corruption, quantify the amount of ill-gotten gains from tainted transactions, and calculate potential disgorgement. We are experienced in interfacing with regulatory agencies to assist in providing fair and accurate reporting of the events at issue.

During the course of or after a bribery or corruption investigation is complete, our experts deliver guidance to organizations and/or their counsel to create remediation plans to help close the gap, monitor, and prevent future problems from occurring. We help to develop and implement anti-bribery and anti-corruption controls and practices that meet international standards and identify internal control weaknesses and opportunities to strengthen ABC programs.

Monitorships

When the DOJ appoints an independent monitor as part of a Deferred Prosecution Agreement (DPA) or Non-Prosecution Agreement (NPA), our experts support the monitor in their evaluation of the company’s ABC policies, procedures, and compliance.

Our team assists the monitor in fact-gathering and interviewing employees at different levels and in various affected geographic regions. Our experts utilize a risk-based approach in transaction testing to evaluate the condition of books, records, and internal controls. Our team utilizes applicable eDiscovery and data analytics strategies in the planning and execution of these monitorships. We have a proven record of effectively coordinating with counsel and monitors and supporting their interactions with the U.S. government.

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