Vetting prospective intermediaries around the world and assessing FCPA risk exposure
A Fortune 500 manufacturing company retained Nardello & Co. to assess its risk exposure and perform an FCPA-focused due diligence exercise to vet prospective intermediaries around the world and determine their compliance with anti-corruption regulations. As part of this assessment, our team reviewed governance policies, training standards, and the results of intermediary due diligence assessments. The investigative team audited high-risk intermediaries in half a dozen countries, completing audits that included background investigations, site visits, interviews, contract analysis, and on-site transaction testing and forensic review. Nardello & Co.’s findings led the client to restructure certain regional distributor and intermediary networks, terminate several intermediary contracts, review internal staffing structures, revise its training program in high-risk jurisdictions, and strengthen its risk matrix.