Investigating FCPA allegations against West African mining operator
Nardello & Co. conducted an 18-month investigation into dozens of allegations of FCPA violations and commercial fraud involving the client’s joint venture mining operations in a West African country. The investigation was highly multidisciplinary in nature, involving discreet interviews with whistleblowers, in-country source inquiries with current and former employees, law enforcement and government sources, technology-assisted and manual review of over a million pages of company documents on eDiscovery platforms, forensic financial review of supplier and project expense history; and open source research in on suspect suppliers in Africa and Europe. Our comprehensive report was used to advise the Board and external counsel on potential US and European regulatory exposure, and to guide the company’s internal controls remediation strategy.