Case studies

RTX Resolves Corruption Allegations

FRA supported RTX and counsel in FCPA related fine calculations.

RTX – formerly known as Raytheon – agreed to pay over $950 million to the US Department of Justice to resolve investigations into

i. a fraud scheme involving “defective pricing on certain government contracts”, and

ii. alleged violations of the US Foreign Corrupt Practices Act (FCPA), Arms Export Control Act (AECA) and International Traffic in Arms Regulations (ITAR) violations.

(DOJ press release, 16 October 2024)

FRA was retained by external counsel to support with fine calculation negotiations with the DOJ. Specialists from our US and UK offices analyzed revenues and expenses to assess the profitability of certain long-term contracts in the Middle East, where the alleged bribery took place. This involved extensive review of company accounting policies and technical accounting topics.

Related contacts

Jenna Voss

Partner & Head of New York Office

,

New York

Toby Duthie

Founding Partner

,

London

Aeriel Houston

Associate Director

,

Dallas

Francesca Caruso

Associate

,

New York

Daniel Roseberry

Associate Director

,

New York

Ruth Blackburn

Senior Associate

,

Dallas

Eric Williams

Director

,

Dallas

Related expertise

Disgorgement and Penalty Calculations

Bribery and Corruption

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Members of our forensic accounting and data analytics teams delivered quarterly virtual training sessions for staff in relevant roles across the 192 National Societies of the International Federation of the Red Cross and Red Crescent Societies (IFRC).

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FRA was engaged by an arbitration panel to act as an independent party, to identify any corruption red flags associated with royalty payments.

ABB

In December 2022, the Switzerland-based multinational technology company reached a “full and final settlement” of $327 million with several national authorities. A multi-disciplinary, international team of FRA specialists supported the company through their cooperation with the authorities over more than three years, from investigation to settlement to compliance remediation.

Petrofac

FRA was engaged by Petrofac and its external counsel to support the company’s plea discussions with the SFO, which had been investigating the company for several years in relation to bribery allegations contrary to the UK Bribery Act.

Airbus

FRA advised Airbus and its counsel from the early stages in designing a robust and forensically based approach to the investigation, customising a data governance strategy alongside compliance risk assessment and remediation support, as well as the eventual fine calculation.

APT Group Cryptocurrency Money Laundering

Reacting to cyber attacks by an Advanced Persistent Threat (APT) group on critical US infrastructure, an FRA Director conducted thorough and sophisticated cryptocurrency asset tracing to identify and disrupt the group's activities.

European Bank

A European bank approached FRA to perform an initial evaluation of its exposure related to customers allegedly involved in money laundering activities. This was of concern to the client given the potential regulatory, financial and reputational implications for the bank.

Nordic Telecommunications Company

FRA was instructed by Telia Company (market cap: over $17 billion) and its counsel in the UK, US, the Nordics and Holland to provide forensic accounting and eDiscovery consulting services in the investigation of the Scandinavian telecoms company.

Cryptocurrency Terrorism Financing

An FRA expert provided critical support to the FBI's Counterterrorism Division, in connection with a multi-agency task force uncovering cryptocurrency terrorist financing. Their efforts led to the most significant US seizure of cryptocurrency to date.

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FRA was retained by external Counsel to represent multiple clients under investigation by the Southern District of New York (SDNY) in connection with the downfall of a prominent cryptocurrency exchange.

International Not-for-Profit Organization

FRA was approached to provide pro bono support to a not-for-profit organization that had identified potential anomalies in its accounting and banking records.

Illicit Online Marketplace

An FRA Director led an investigation into a nefarious online marketplace, applying complex data analysis resulting in the arrest of numerous cybercriminals selling illicit goods and services.

Cryptocurrency Exchange Collusion

When a new cryptocurrency experienced sudden delisting from multiple exchanges, their Counsel urgently engaged an FRA partner to help investigate potential antitrust or collusive behavior.

Rolls-Royce

Rolls-Royce plc, the UK-based manufacturer and distributor of power systems for the aerospace, defense, marine and energy sectors, was under investigation by the US Department of Justice (DOJ), UK Serious Fraud Office (SFO) and Brazilian authorities in relation to an alleged long-running scheme to bribe government

Sanctions and the Russia-Ukraine War

An FRA expert was responsible for monitoring and investigating cryptocurrency sanctions exposure originating from the Russia-Ukraine war to protect customers from sanctions violations.

Multinational Transport Engineering Company

FRA was retained by US counsel to Alstom (market cap: over $10 billion) to assist with defending a US securities class action suit. The case involved allegations around export credit financing of a division that Alstom had sold to a third party.

Class-action Lawsuit challenging Solitary Confinement in US Prisons

FRA was approached by our client, White & Case, to provide pro bono support to the ACLU in their federal class-action lawsuit seeking to end solitary confinement in two Virginia prisons.

UN Oil for Food Program

As part of a UN investigation into possible corruption in the Iraqi Oil-for-Food program, FRA carried out a forensic accounting review and eDiscovery exercise.

Technip

Following the imposition of a monitor in a joint resolution by the US Department of Justice (DOJ) and US Securities & Exchange Commission (SEC), Technip retained FRA to review the company’s anti-bribery measures and export control compliance program, provide forensic accounting and eDiscovery services and train the client’s internal audit staff to autonomously conduct future internal reviews.