This client, a manufacturer of telecommunications and network technology and equipment, had conducted an internal investigation regarding a kickback scheme allegedly carried out by three of their sales managers in South America. The client took a variety of steps in the investigation, including completing a pricing analysis, due diligence, credit checks, and conducting interviews to gain more information. Based on the steps taken, the client concluded that the three implicated individuals were not likely to have received kickbacks.

The client engaged us to provide a wholesale review of their investigation, evaluate the appropriateness of the steps taken, and recommend any additional work that may need to be done to ascertain the truth.


We began by reading the client’s investigation report to gain an overview of all of their investigation steps. Next, we reviewed some of the original documentation, such as the whistleblower’s letter and due diligence reports compiled by one of their outside vendors. Finally, we produced our own report, evaluating the strengths and weaknesses of the client’s investigation and listing recommended additional steps for the client to take to gain a fuller picture of the events that allegedly transpired.

In this case, we recommended that additional, more thorough due diligence should be conducted on the distributor, the three implicated individuals, and two other individuals who had potential links to the distributor.

We then appointed our due diligence investigators to carry out a review on all five subject entities. Based on the due diligence carried out, we were able to determine that at least two of the individuals reviewed had potential ties to the distributor, making the kickback scheme a real possibility.


  • Investigation report – one week
  • Due diligence reports – six weeks