We were retained by a publicly traded US company with subsidiaries in Latin America to investigate possible FCPA violations when it discovered that one of its primary consultants in Mexico, tasked with negotiating contracts with Mexican government agencies, had asked the company to direct his consulting payments to several third party entities.
In the course of the investigation, we determined that certain country managers might have been complicit in allowing the questionable payments to be made. Our teams in Mexico and elsewhere in Latin America conducted interviews and captured forensic evidence from in-country computers on behalf of the parent company. A comprehensive investigation of the consultant revealed that one family member was a Mexican government official—a fact which had not been previously disclosed—and that another family member was suspected of money laundering for the cartels.
It was ultimately determined that the consultant was using the third party payees as part of a personal tax evasion scheme but was not engaging in conduct in violation of the FCPA.