Companies that conduct business globally need to be proactive in their compliance in the face of growing regulatory requirements.
In today’s regulatory environment, complying with domestic and international laws and regulations has become an increasingly difficult challenge for financial institutions, private equity firms, hedge funds, casinos, and other local and international corporations. Regulators across the globe have increased their scrutiny of financial institutions and corporations’ domestic and international activities, business development efforts, and banking and money laundering compliance policies. As a result, companies that conduct business globally need to be proactive in their compliance with growing regulatory requirements regarding reporting, anti-money laundering, trade, and sanctions, as well as the increased enforcement of the UK Bribery Act, and the Foreign Corrupt Practices Act (FCPA), among others.
Successfully managing the risks arising from this increased scrutiny requires a deep understanding of the technical legal requirements of multiple jurisdictions, as well as the investigative methods used by government regulators and criminal prosecutors. Exiger’s exceptional investigative capabilities, international presence, deep industry knowledge, and extensive practical experience make us the ideal choice to help tackle regulatory concerns. That understanding is enhanced by our team members’ regular interaction with banking clients, regulators, and law enforcement agencies around the world, including the U.S. Department of Justice (DOJ), the Federal Reserve Board (FRB), the UK Financial Conduct Authority (FCA), among others. Several of our professionals have backgrounds in law enforcement and have served in the government agencies responsible for enforcing these laws. We leverage our longstanding experience with domestic and international regulatory bodies and law enforcement agencies to better inform our clients of regulatory expectations.
Around the world, our teams work with financial, and non-financial U.S. and multinational institutions to thoroughly investigate potential violations of the Bank Secrecy Act (BSA), the Patriot Act, OFAC and other sanctions regulations. Our services also include both conducting internal investigations on behalf of companies into the potential wrongdoings of employees, and performing external investigations and diligence reviews into the conduct of affiliates and other third parties. Our investigative team, composed of former FBI agents, federal and state prosecutors, forensic accountants, cyber forensic experts, and financial crime compliance experts can effectively and efficiently draw evidence from large and disparate sources of data because we know what to look for and how to find it.
Exiger is also well-versed in working with both in-house and outside counsel to uncover the facts underlying potential frauds. Once a potential violation of a relevant law or regulation is uncovered, our seasoned teams will further investigate to ensure the client is aware of all relevant facts. Armed with this detailed intelligence, our clients can then make an informed strategic decision about how best to proceed.
Regulatory Investigations Case Studies
FCPA Violation Allegation Investigated
An Exiger Associate Managing Director conducted an FCPA investigation for a U.S.-based media company regarding parties involved in bidding for media rights related to soccer tournaments in the Americas. The investigation uncovered several individuals later identified as unindicted co-conspirators in the May 2015 FIFA indictment.
Multi-Billion Dollar Online Gaming Industry Shuttered in U.S.
An Exiger Managing Director led a seven-year criminal investigation in the Southern District of New York into the illegal online gaming industry. The gaming companies had established an elaborate system of shell corporations, intermediaries, and payment processors around the world to move billions of dollars from customers in the U.S. overseas. Through detailed analysis of bank statements, ACH transactions and wire-transfer data, public record searches, source development, and detailed asset tracing, the investigators traced these payment networks and seized more than $1.5 billion, which was forfeited. The case also resulted in the convictions of the main stakeholders of the largest online poker companies in the world and the eradication of these gambling websites in the United States.
Alleged Corruption Scrutinized in Thailand
An Exiger Director conducted an FCPA investigation involving an agent/customer relationship in Thailand for a U.S.-based manufacturing company. This involved a comprehensive review of transactional activity, relevant documentation, and emails.