A Ukrainian finance group found itself being de-risked by Western financial institutions as a result of allegations made in the public domain accusing it of being complicit in financial wrongdoing notably on behalf of Ukrainian PEPs, including former presidents. The client disputed these allegations and sought an independent review to clarify the position.
The audit gathered all of the allegations in the public domain relating to the client and which would be visible to potential counterparties. The client was then interviewed to understand their response to the allegations and why they considered them to be inaccurate. A forensic investigation of the allegations followed based on unfettered access to client records, access to current and former client employees, open source research, and human source intelligence gathering. The local context – including political and business influences – was examined and an independent review into each of the allegation was prepared and submitted to the client’s legal advisers.
The report documenting the findings of the review was shared with the compliance functions of counterparties which allowed for a more nuanced assessment of the risk position relating to the client.
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