From Philippines to Cayman Islands

Nardello & Co. was engaged by a US manufacturing company to conduct an FCPA investigation into one of its sales agents in India amid whistleblower allegations that the agent had “problematic” ties to various state-owned enterprises. Our open-source research identified media reports alleging that the agent had been implicated in crimes including embezzlement, fraud, money laundering, and bribery of government officials. We identified and interviewed former employees of the agent, some of whom provided details substantiating the allegations. Research uncovered similar illegal and unethical behavior by the sales agent on behalf of other companies in the sector. Discreet law enforcement inquiries confirmed the agent was the target of a criminal investigation. The client used our findings to inform their legal strategy to mitigate FCPA liability.