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.
Scott Carnahan is a Senior Advisor to Secretariat based in Orange County, California. Mr. Carnahan has more than 40 years of accounting, consulting and management experience in the financial institutions industry.
Mr. Carnahan is a Certified Public Accountant with a focus on various types of financial institutions including banks, non-banks, mortgage banking companies, independent finance companies, investment companies and captive finance companies which participate in commercial and consumer lending. While serving as a Partner at KPMG LLP (KPMG) from 1982 through 2007, he was responsible for the firm’s structured finance practice and assisted in the issuance of over 20,000 structured finance transactions (worth a combined total of more than $3,000,000,000). In addition, Mr. Carnahan served as acting CFO at a publicly traded mortgage company and President of a national mortgage lender. He has extensive experience with debt and equity securities and commercial and consumer lending.
At KPMG, Mr. Carnahan served as a National Director of KPMG’s Advisory Services, directing audit and consulting resources on major projects nationally. He has significant SEC reporting experience including initial public offerings (IPOs), debt and equity offerings, restructuring, and assisted many institutions with restatements.
Mr. Carnahan has audited and consulted with numerous bank trustees, custodians and safekeeping operations related to initial and ongoing securitization transactions including compliance with Reg AB. His responsibilities have included working with clients that originated and serviced a large proportion of the consumer loans nationally. He is currently a Board of Trustee member for a public mortgage REIT (PMT).
Mr. Carnahan has served as an expert witness in numerous court cases including both deposition and trial testimony.
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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