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.
Zhao Xuan (“Alex”) is a Manager in Secretariat’s Global Investigations and Disputes practice, based in Singapore. He is a Chartered Accountant and Certified Fraud Examiner with experience spanning forensic investigations, compliance advisory, financial audit and assurance engagements across multiple industries.
Singapore
Mr. Toh brings experience in white-collar crime investigations, including accounting fraud, asset misappropriation, conflicts of interest, and procurement kickback and collusion schemes. His experience extends to compliance engagements such as anti-bribery and corruption framework reviews, risk assessments, training, and internal control evaluations. He has also been engaged in regulatory matters involving the U.S. Securities and Exchange Commission (SEC), the U.S. Department of Justice (DOJ), and Singapore’s Corrupt Practices Investigation Bureau (CPIB).
Mr. Toh began his career in professional audit practice at a Big Four accounting firm, specializing in listed companies in the aviation and energy sectors, with a focus on financial reporting, internal controls, and risk-based financial analysis. He subsequently worked as a Senior Consultant in a multinational consultancy firm, where he supported forensic investigations and dispute-related engagements across various industries, before joining Secretariat.
His key areas of expertise include fraud risk assessment, forensic accounting investigations, anti-bribery and corruption framework development, ISO 37001 Anti-Bribery Management System certification projects, internal controls evaluation, and regulatory support matters. He has experience working across industries such as construction, transportation, automotive, oil & gas, and energy, supporting both private and public sector clients.
He is fluent in English and Chinese (Mandarin).
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.