In recent years there has been an increased focus on enforcement actions by the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) in regard to the Foreign Corrupt Practices Act (FCPA), with particular attention to violations of the books and records provision. Accordingly, the need for forensic accounting experts who understand the nature of non-U.S. operations is of critical importance for companies at risk of committing a FCPA violation.
Hemming Morse has nearly twenty years of extensive experience with the FCPA, including a Compliance Monitoring assignment in 2005. Partner Dan Ray is a former FBI Special Agent with the unique qualification of having been appointed on two separate occasions by the DOJ and SEC to serve as the Compliance Monitor for companies under deferred prosecution agreements. In addition, he has also served as an “informal” FCPA Compliance Monitor for four years for a pharmaceutical company. As part of their work, Hemming Morse professionals have traveled throughout Asia and Europe for its work with companies or as an independent monitor.
Our team of professionals work closely with in-house counsel, compliance officers, audit committees, and outside counsel to provide collaborative, efficient, and cost-effective investigations and compliance monitoring services. From monitoring, to preventative counseling, to transaction due diligence, Hemming Morse has the required and distinct experience and skills.