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.
A global online retailer was the victim of a sustained and widespread fraud caused by an online campaign targeting the retailer’s returns policy. In addition to the monetary losses, the client was concerned as to the potential impact that an investigation and subsequent remediation actions may have on its customers seeking genuine returns.
An intelligence gathering exercise identified an online industry targeting the online retail sector in which online users offered to secure a fraudulent refund in return for payment. These services were typically promoted via hacking and gaming websites. The intelligence was used to identify the key websites and the larger players in this space which then became the targets of the investigation. Open-source research was undertaken to generate information on the targets and, where possible, identify the individuals behind the online profiles. Following this, test purchases of the offered fraud services were conducted and this generated further information on the individual involved together with a funds flow which identified the beneficiary of the fraud. These details were compiled into dossiers and provided to law enforcement agencies around the world.
The investigation led to arrests and convictions of fraudsters, the news of which was disseminated across the relevant websites to create a deterrent message. Where necessary, legal action was taken against websites hosting content offering fraudulent services. The client was also supported through revisions to its internal processes for identifying red flag refund claims and subsequent customer service interaction procedures.
There was a significant decline in the number of fraudulent refund losses and the almost complete removal of fraudulent services targeting the client from websites.
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.
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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.