Nardello & Co. was engaged by a US multinational to conduct an FCPA investigation into allegations that one of its distributors in China had paid bribes to local government officials on the instructions of a regional sales manager to secure a large contract.

As part of the investigation, we interviewed a number of executives of the client’s China subsidiary and its distributors, and conducted a forensic review of the subsidiary’s sales data, pricing lists, distributor agreements and other relevant books and records. We also reviewed the computer files and email correspondence of employees implicated in the matter. In addition, we conducted public domain research and discreet human intelligence inquiries into the distributor in order to determine the nature of his political connections with the local authorities.

As a result of our inquiries we were able to identify evidence to substantiate the allegations.