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.
Mr. Kelly specializes in matters involving complex data manipulation and analysis of disparate data sets to provide comprehensive, data-driven insights. He also has years of experience working with semi-structured data and creating pipelines / automating processes for ensuing analyses. Examples of prior engagements include:
- A Price Fixing allegation where he supported a Joint Defense Group. Mr. Kelly developed scripts to capture key details from communications existing across thousands of semi-structured PDF documents, created a pipeline for systematic and repeatable transfer to a centralized database, and performed analysis to identify key communications between relevant parties.
- An Investigation for a large Social Media Company into potential Data Privacy and Compliance issues. Mr. Kelly’s team established a risk-based approach to identify third parties that could have accessed a significant amount of data – one aspect of this review involved Mr. Kelly creating an algorithm to determine high-risk third parties based on trends in historical activity on the company’s platform.
- Data Management for the Recovery of over $800M in fees from a 15-year International Litigation. Mr. Kelly programmatically transposed narrative information, identified outliers / issues for counsel review, and prepped for detailed tagging and claim confirmation. Mr. Kelly managed data receipt from multiple parties and led a large team in confirming manual data extraction and reconciliation for supplement to the award.
- An International Anti-Money Laundering Investigation into account populations and transaction history. Mr. Kelly assisted with the development and implementation of key custom tools / approaches used to classify potential accounts associated with individuals of interest based on KYC information and historical activity (customer and transaction screening).
- Analysis of Historical Lending Activity of a large online driven bank for Compliance with Fair Lending requirements.
- A review of hundreds of Gigabytes of data in varying nested formats (CSV, JSON, and XML / HTML) included in a Data Breach to identify the breadth of potential PII / account information exposed.
- An Investigation into account activity of all users on a Cryptocurrency Platform for actions potentially indicative of insider information surrounding key transactional dates.
Mr. Kelly’s primary technical proficiencies include Python, SQL, and Tableau.