Internal Investigations

The need for an internal investigation may have many possible causes – sometimes before external regulatory action, or for internal reasons. Establishing its exact purpose will determine the scope of the work required at the outset. Every internal investigation should be based on establishing the facts – to determine exactly what happened before any conclusions are reached on liability or the next steps to be taken.

Whatever the cause, we help our clients act quickly and decisively in conducting internal investigations into corruption, fraud, or other types of financial misconduct. Our experience enables us to combine an understanding of different business sectors and cultures to achieve an effective result.

We carry out complex investigations for all types of business across a broad range of sectors with specialist expertise in financial services, as well as in the operations of small to medium sized businesses.  We implement reviews into corruption, money laundering and fraud risk, as well as accounting integrity and conduct, including accounting irregularities and professional disciplinary issues.

Our forensic technology expertise enables us to deliver advanced technological solutions in the retrieval, search and analysis of complex data sets. Our clients can then have access to information that may be used to deal with litigation matters and regulatory requirements.

Internal Investigations

International Bank Money Laundering Data Analysis

Honeycomb was instructed when a small international bank with a presence in 6 countries was concerned that it was being used to facilitate money laundering. Clearly the risks of this to the bank both operationally and in regulatory terms was immense. Honeycomb was able to deploy its DATAcomb range of data analytic tools to create a risk algorithm and threat profile with which it then trawled through 1.7 million transactions over 4 years. The first results highlighted a number of issues in a threat hierarchy. At the top of the pyramid were 42 data sets covering all 6 countries, 164 account holders and a little over 3,000 transactions. The investigation and use of DATAcomb led to all account holders being removed, a number of intermediary entities including lawyers and accountants being implicated in facilitating money laundering, and two of their own bank managers being suspended and prosecuted. The Bank calculated that the investigation had saved them millions in terms of avoided fines, and an incalculable amount in terms of preserved integrity and reputation.

Tracing Analysis into Corruption Conspiracy

Honeycomb was instructed in a large tracing exercise as part of a dispute over a corruption conspiracy. Although the number of transactions was not large, only 80,000, the benefit of using data analytics is that it exposes trends and relationships and demonstrates robustly what transactions are high risk, and which low. The application of DATAcomb in this case allowed, first, the facts of the case to be properly set out and analysed, the transactions to be set out in an orderly and manageable format, and the risk profile of individual transactions to be assessed. As a result of our work, a small number of transactions were identified with an unacceptable risk profile. These were then subjected to more substantive testing at the end of which it was determined that there was insufficient evidence of corruption.

For further reading:

•   E-disclosure Platforms  •  Digital Forensics   •  Asset Tracing  •  Information and Intelligence Gathering