Improper Payments in Latin America – Peru, Chile, Brazil and Mexico

A global services provider was alleged to have made improper payments in multiple Latin American countries in exchange for the award of government contracts. These payments were alleged to have been made through a series of business intermediaries and other vendors in an effort to disguise them as legitimate business expenses. WCF personnel oversaw a retroactive review of vendor disbursements in each country and also devised, implemented and administered a review of payment requisitions prior to any payments being made a going forward basis. This payment requisition review team also identified numerous internal control shortcomings which they were able to share with the finance team enabling them to make timely remedial actions. After several months of performing this vital payment requisition review function, the team successfully transitioned the process to a full-time team in each country. This work, together with several other work streams, enabled the company and outside counsel to successfully negotiate settlements with the DOJ, SEC and several foreign government agencies.