StoneTurn’s Global Bribery, Corruption & Foreign Corrupt Practices Act (“FCPA”) practice includes professionals who have assisted many clients in worldwide foreign bribery investigations, compliance and due diligence efforts.  Our global Bribery, Corruption & FCPA practice focuses on foreign bribery investigations, compliance, and independent monitoring.

• Investigations – utilizing our professionals’ prior experiences working at the Securities and Exchange Commission (“SEC”), Serious Fraud Office (“SFO”) and Big Four accounting firms conducting foreign bribery investigations, we assist clients in worldwide investigations.  We provide an in-depth understanding of how the SEC conducts investigations of FCPA violations, specifically the Books and Records provision.
• Risk Assessment, Compliance and Monitoring – utilizing our prior experiences, we assist clients assess their specific industry and geographical vulnerabilities and institute remedial steps to mitigate their risks.  We offer expertise in fraud and corruption prevention policies and protocols and assist in enhancing existing controls or creating and implementing new ones.  We also provide employee training about red flags and response strategies, ensuring prompt detection through automated systems, and developing effective internal incident reporting mechanisms.
• Transactional Due Diligence – assisting clients in analyzing potential foreign bribery red flags both in the financial information available and information outside of the diligence process (pre-transaction), and evaluating the integration of an acquired company and their policies, processes and protocols (post-transaction).  We can evaluate a target’s compliance program, including how they vet third party consultants and agents, coordinate government sales activities and approve paid travel or entertainment of government officials.
• Independent Monitoring – working with companies as an independent monitor or consultant in response to a settlement or judgment.  We offer expertise in providing independent, ongoing compliance with foreign bribery programs.

All of our partners hail from “Big Four” accounting firms, as well as a former Branch Chief at the SEC who assisted the SEC in investigating foreign bribery matters.  Our practitioners include former financial statement auditors and seasoned investigators with extensive experience conducting FCPA investigations and assisting companies on proactive approaches to combat FCPA violations. 

For more information please contact Kevin Bennett, Deirdre Flaherty, Rex Homme, Anthony Jordan, or Mark Hair