Article | June 30, 2026
FCPA Enforcement: Where the Bribery Actually Happened
FCPA enforcement trends analyzed by geography. Discover where bribery risk is concentrated and how it impacts global compliance, investigations and risk management.
The Claimant was a publicly traded junior mining company that owned a development stage gold mine in a foreign jurisdiction. The Claimant alleged that its mining concessions were wrongfully terminated by the government of that jurisdiction.
Secretariat professionals were engaged by the Claimant to quantify the economic damages it allegedly sustained in connection with its ICSID claim against the government that terminated its mining concessions.
We prepared a valuation of the gold mine using the discounted cash flow method, based on a robust financial model that incorporated the forecasted revenues, costs and technical aspects of the mine, as well as the economics of the gold market at the valuation date. In addition, we considered various market-based valuation methods to test the reasonability of our conclusions under our primary valuation approach.
We also filed a report in connection with the jurisdictional hearing, whereby we analyzed the date at which the Claimant’s investment in the gold mine became substantially worthless, based on our detailed review and analysis of financial data and public disclosures. The Claimant was ultimately successful at its jurisdiction hearing.
We testified on valuation and economic damages issues at a hearing held at the World Bank in Washington, D.C.
FCPA Enforcement: Where the Bribery Actually Happened
FCPA enforcement trends analyzed by geography. Discover where bribery risk is concentrated and how it impacts global compliance, investigations and risk management.
Secretariat is pleased to share that 56 of our experts have been recognized in the Lexology Index 2026 Construction report for their outstanding work on complex construction disputes and claims around the world. With 12 experts named as Global Elite Thought Leaders—the report’s most exclusive ranking, achieved by only 5% of listed professionals—Secretariat has earned the No. 1 spot in this category for the second year in a row among more than 750 ranked firms.
Eric Poer, a Managing Director in Secretariat’s Global Investigations & Disputes practice, was retained by the U.S. Securities and Exchange Commission (SEC) to serve as their forensic accounting expert in a high-profile securities fraud dispute.