Nardello & Co. was retained by a Fortune 500 company considering the acquisition of an international company with subsidiaries in Asia and Africa. The client was concerned that local agents acting on behalf of the subsidiaries may have been guilty of FCPA violations that would derail the acquisition.

No actual FCPA violations were identified but our investigation determined that certain subsidiaries were particularly vulnerable to corruption issues. As a result, the client planned to proceed with the acquisition, with the understanding that certain subsidiaries would be closed or sold to minimize the company’s exposure to problematic business practices.