Uncovering the truth and a family affair
A US public company with Latin American subsidiaries retained Nardello & Co. to investigate possible FCPA violations when it discovered that one of its primary consultants in Mexico, responsible for negotiating contracts with government agencies, had asked the company to direct his consulting payments to third-party entities in Mexico and another Latin American country. Nardello & Co. sent investigative teams to both countries to conduct interviews and capture forensic evidence from company computers. Our team determined that certain country managers may have been complicit in allowing the questionable payments to be made. A comprehensive investigation of the consultant revealed that one family member was a government official—a fact not previously disclosed—and that another family member was suspected of laundering money. We determined that the consultant was involved in a personal tax evasion scheme, not engaging in conduct that violated the FCPA. Based on Nardello & Co.’s findings, the company handled the matter internally.
