As government enforcement actions around anti-corruption—specifically, the U.S. Foreign Corrupt Practices Act (“FCPA”) and equivalent laws and regulations in Europe—continue to rise, companies doing business outside the U.S. must take a much more proactive approach to mitigating the related risks.
The U.S. Department of Justice (“DOJ”) has introduced several new measures to increase prosecution of individuals for FCPA violations, including a one-year pilot program intended to motivate companies to voluntarily self-disclose FCPA-related misconduct, fully cooperate, and remediate flaws in controls and compliance programs. This increased level of scrutiny requires companies to address the numerous complex issues surrounding anti-corruption risk management, internal control compliance and training, as well as to conduct robust investigations into allegations or “red flags” indicating possible non-compliance.
How We Help
StoneTurn assists to identify, investigate and monitor potential violations:
Compliance & Risk Assessments
StoneTurn assists companies and counsel in performing gap analyses to identify and assess potential vulnerabilities that could lead to FCPA violations, then assists with the design and implementation of an effective anti-corruption compliance program.
StoneTurn helps companies to develop successful proactive transaction monitoring programs to create key risk indicators of corruption, develop data tests to identify risk indicators, and train resources how to appropriately investigate and document the response to suspicious transactions.
StoneTurn helps companies and counsel to collect and assimilate data from disparate sources, analyze large and complex databases and identify data anomalies, outlier transactions, and business trends to assist in investigating allegations of corruption and bribery.
StoneTurn professionals have served as court- and government-approved independent monitors, following FCPA settlements with the DOJ, SEC and other regulators.