Article | June 30, 2026
FCPA Enforcement: Where the Bribery Actually Happened
FCPA enforcement trends analyzed by geography. Discover where bribery risk is concentrated and how it impacts global compliance, investigations and risk management.
A bank was defrauded of US$150 million as a result of fraudulent transactions entered by an internal team of traders.
Having confirmed the trades through which the funds were misappropriated, the proceeds of the fraud were forensically traced using a combination of disclosure mechanisms (including Norwich Pharmacal orders, Section 1782 orders, and requests of overseas prosecutors), open-source research, and human intelligence sources. The proceeds had been laundered through structures and assets – including diamonds, Ferraris, and real estate – spread around the world including Azerbaijan, the Bahamas, Georgia, Israel, Latvia, Lithuania, Russia, Seychelles, Spain, Switzerland, UK, Ukraine, and the U.S. The tracing exercise enabled external legal counsel to obtain freezing orders and, ultimately, the repatriation of value.
The client recovered significant funds and the findings from the investigation contributed to two of the fraudsters receiving custodial sentences.
FCPA Enforcement: Where the Bribery Actually Happened
FCPA enforcement trends analyzed by geography. Discover where bribery risk is concentrated and how it impacts global compliance, investigations and risk management.
Secretariat is pleased to share that 56 of our experts have been recognized in the Lexology Index 2026 Construction report for their outstanding work on complex construction disputes and claims around the world. With 12 experts named as Global Elite Thought Leaders—the report’s most exclusive ranking, achieved by only 5% of listed professionals—Secretariat has earned the No. 1 spot in this category for the second year in a row among more than 750 ranked firms.
Eric Poer, a Managing Director in Secretariat’s Global Investigations & Disputes practice, was retained by the U.S. Securities and Exchange Commission (SEC) to serve as their forensic accounting expert in a high-profile securities fraud dispute.