When FCPA allegations were made against the European subsidiary of a major US pharmaceutical company, Nardello & Co. was retained by the company’s audit committee to conduct a wide-ranging investigation into whether bribes had been paid to government officials.

The investigation involved in-depth analysis of numerous business documents as well as interviews with key personnel of the subsidiary and the relevant government officials. 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 location.

The investigation spanned several months, identified improper activity and resulted in the company adopting Nardello & Co.’s recommendations for enhanced compliance procedures.