Maintaining Compliance Procedures Worldwide

FCPA Investigation - US and Europe

When FCPA allegations were made against the European subsidiary of a major US pharmaceutical company, Nardello & Co. was brought in by the company's audit committee to conduct a wide-ranging investigation into whether government officials had been bribed. The investigation involved in-depth analysis of numerous business documents as well as interviews with key personnel of both the pharma subsidiary and the government. When initial findings of accounting irregularities resulted in the expansion of the investigation to six additional countries, Nardello & Co. sent a team of auditors and investigators to each. The investigation spanned several months, identified improper activity and resulted in the company adopting Nardello & Co.'s recommendations for enhanced compliance procedures.