Managing a multi-language FCPA investigation is not a trivial undertaking. Most inquiries involve thousands, if not millions, of documents collected from multiple locations around the world. The files are likely to be in a variety of formats ranging from ASCII and Unicode to Big 5 (Chinese) or Shift-JIS (Japanese). Content is likely to span several languages reflecting the dialects of each involved office. In many cases, documents will include multiple languages that will have to be searched and reviewed.
Catalyst has been working with corporations and their counsel on worldwide FCPA investigations and reviews for many years. Here are several reports on the different kinds of matters we have handled:
1. Catalyst CR Helps Client Complete Worldwide FCPA Investigation Involving 1.3 Million Documents in Over 12 Languages.
With the stock market at record levels, a large private equity fund sought to spin off its energy company through an IPO. The company had activities in over 20 countries across Europe, Asia, the Middle East, Africa and Latin America. The fund wanted to make sure that no potential issues existed under the Foreign Corrupt Practices Act or other anti-bribery legislation before filing for the IPO. To accomplish this objective, the company retained a Global 5 law firm to oversee an internal investigation. The investigation needed to be prompt as well as thorough given that the window for a successful IPO could close at any time.
The purpose of the investigation was to unearth any potential issue in any location where the company operates. This meant collecting 1.3 million documents totaling 400 gigabytes from operations in countries around the globe. While English served as the company's primary operating language, local language documents abounded. In all, the documents contained over a dozen languages, including Russian, Hebrew, Spanish, French, Chinese, German, Arabic, Korean, Japanese and Ukrainian. In many cases, individual documents contained multiple languages.
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2. Catalyst Helps FCPA Review Team Manage a Four Million Document Multi-Language FCPA Review
An AmLaw 10 firm asked Catalyst to assist with a high-stakes FCPA investigation. "Drives are being flown in from Russia, Spain, Brazil, China and several other countries," our client explained. "We need these files loaded, analyzed and reviewed in less than two months," he added. "Can you meet the plane to pick up the drive being hand-delivered from Brazil?"
Like many FCPA investigations, this one involved emails, spreadsheets, Word files and other documents in a number of different languages, more than 25 at final count. While the law firm had bilingual attorneys on staff, they did not have people who could cover all of the possible languages. Because of secrecy concerns, the client did not want to bring in outside reviewers.
Read the full Case Study . . .
3. Catalyst Consulting helps Client find Potentially Privileged Documents before Production in a DOJ Investigation.
Our client faced a Department of Justice investigation stemming from a takeover bid by a third party. The General Counsel was not happy with the situation for two reasons: first, the takeover was hostile and second, the DOJ demanded almost all of the corporate files. Review costs were seen as simply adding insult to injury. And, the deadline was tight. They had days rather than weeks to respond.
The client determined to produce everything to the DOJ. Counsel was directed to screen for privilege only. Catalyst Consulting was asked to assist in the process.
Read the full Case Study...
For more than a decade, Catalyst has provided legal professionals with a secure, scalable search and review platform for FCPA investigations and other complex legal matters. Our consultants can work with you to develop search and review strategies and we can provide multi-lingual review professionals to supplement your team. Contact a Catalyst representatives to see how we can assist your FCPA investigation.