Case study 1: Anti-bribery and corruption investigation in Portugal

It alleged that the Operations Manager has been receiving commissioning payments from suppliers. It was also alleged that suppliers were onboarded and created, in order to facilitate these fraudulent payments. The investigation was undertaken and coordinated by the Forensic and Investigation Services team in London with the support of the UK forensic technology team and the team in Portugal.

We undertook a full email review of the subject’s mailboxes as well as due diligence checks in relation to a list of 20 companies that were alleged to have been set up to facilitate the commissioning payments to the Operations Manager.

Finally, we reviewed the process for supplier onboarding and the invoicing/goods receipt process to identify if this was robust enough. We identified weaknesses in the procedures that required strengthening from an anti-bribery and corruption perspective. Although the investigation did not prove that bribery had been occurring in the organisation we were able to provide them with recommendations on how their processes could be strengthened in order to prevent bribery from occurring in the future.

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