CASE STUDY #2
Multi-national FCPA Investigation for an International Software Company
Through Special Counsel
The software company desired to conduct an internal investigation into allegations of payments that may have implicated the Foreign Corrupt Practices Act.
During the course of the investigation, the UHY Advisors’ team investigated the activities and records of the corporation and its foreign agents in Russia, the former Baltic Republics, Holland, China, Indonesia, Saudi Arabia, Israel, Mexico and Nigeria. In the course of the investigation the team uncovered instances of inappropriate payments being made to government officials, above market payments being made for leased assets, and travel benefits being provided to non-employees with ties to governmental bodies. We assisted our client in conducting interviews, translating documents from Chinese and Hebrew into English and participating in meetings with internal audit committee members as well as the company’s outside auditors.
UHY Advisors, working with special counsel, identified numerous instances of highly suspect payments, and other non-cash benefits, being offered to government officials and/or their relatives. As a result of our investigation, a number of remedial actions were identified for implementation. In addition, we quantified the amount of gross profits subject to potential forfeiture.