Compliance review for European gas and oil business

oil, gas, and LNG


  • Justin Cooper was instructed to assist Compliance Counsel appointed under a Deferred Prosecution Agreement entered into between a European headquartered oil and gas business and the US Department of Justice for alleged US Foreign Corrupt Practices Act offences.
  • Performed compliance reviews of historical activity in over 15 international locations of the oil and gas business.
    Identified historical instances or suspicions of corruption (under UK, US and Norwegian law) and to test and make recommendations in relation to internal controls, policies and procedures.


  • Developed a series of data interrogation tests to run across client data to highlight instances of potential corruption.
  • Extracted millions of lines of data, from dozens of different accounting systems worldwide; including: Accounts Payable, Accounts Receivable, General Ledger, Payroll and expenses
  • Developed over 30 separate analysis to create exception reports, to highlight suspicious and potentially corrupt transactions.


  • The data mining skills and techniques allowed every transaction to be analyzed, rather than the more standard random sampling.
  • Quickly and efficiently identified potentially corrupt transactions that required further investigation.
  • Identified transactions with countries which were not known or approved within the Group. The team discovered that the payments had been made to agents in these high-risk countries which was strictly against company policy and heightened the risk of corrupt payments being made to government officials. This information was provided to Compliance Counsel for further investigation and use in interviews of key personnel.