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Notable Cases

Corporate Officer and the Foreign Corrupt Practices Act

A prominent corporate officer in a Fortune 100 company was the focus of a federal grand jury investigation into overseas bribery. He faced the loss of his stock, forfeiture of his home - not to mention jail. (The Foreign Corrupt Practices Act prohibits U.S. companies from "corruptly" making any payment or providing anything else of value, for various business purposes, to foreign government officials.) Rather than waiting to see what would happen, we launched an aggressive international investigation that consisted of interviewing managers, consultants, brokers, dealers, and agents that participated in the deal. A forensic accountant was used to examine all contracts, licenses, payments, and other information that would identify any accounting irregularities. We presented evidence that showed that there was no bribe or conscious disregard of dishonest behavior. The Department of Justice dropped the investigation.


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