StoneTurn’s Foreign Corrupt Practices Act (“FCPA”) practice includes professionals who have assisted many clients in worldwide FCPA investigations, compliance and due diligence efforts.  All of our partners hail from “Big Four” accounting firms, including a former Branch Chief at the Securities and Exchange Commission who assisted the SEC in investigating FCPA 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. 

Our FCPA practice focuses on:

FCPA Investigations

• Investigations – utilizing our professionals’ prior FCPA experiences working at the SEC and Big Four accounting firms conducting FCPA investigations, we assist clients in worldwide investigations.  We provide an in-depth understanding of how SEC investigations view violations of the FCPA, specifically the Books and Records provision.

FCPA Compliance

• 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 FCPA 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 Monitors and Consultants

• 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 FCPA programs.

Along with a strong technical accounting background, our practitioners utilize their fraud training and experiences in providing thorough, efficient and independent investigative services to our clients.  We offer highly technical expertise and solutions for every step of our clients’ investigative, due diligence and risk assessment, compliance and monitoring matters.

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