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.
The year-end financial reporting process of a British university identified financial irregularities that prevented the completion of its statutory audit. The absence of a signed-off audit by the submission deadline would have breached financing covenants resulting in the university defaulting on its finance agreements.
The university’s finance manager confessed to having embezzled funds over a 30-year period but would not provide the details as to how the fraud had been concealed, where it sat within the accounting system, or the value of the fraud. The investigation required a forensic review of the accounting system for suspicious transactions together with an understanding of the accounting processes in place which could have been subverted to allow the fraud to be disguised. Ultimately transactions running into the millions of pounds were identified within an array of creditor balances that accounted for much of the fraud.
The findings of the investigation allowed the external auditors to correct the financial statements to provide an accurate position of the university’s financial position which, in turn, ensured compliance with the finance agreements. In addition, the findings were used by the police to secure the conviction of the finance manager and to freeze assets which were subsequently recovered for the benefit of the university.
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.