Relevant Experience

SEC and Regulatory Enforcement Defense Assistance

• As an enforcement accountant in the SEC Division of Enforcement, conducted numerous investigations into securities violations with a primary focus on financial statement fraud, improper accounting and auditor malpractice.
• Assisted management of a Korea-based technology company and a US-based global consumer packaged goods company in connection with SEC investigations of various accounting and disclosure issues.
• Assisted outside counsel in the defense of an SEC investigation into the independent audits performed by a national accounting and advisory firm.  Prepared witnesses for SEC testimony.
• Provided forensic accounting services to an unregistered investment advisor in connection with its investment management services provided to several hedge funds.
• Assisted the company in reviewing and reconstructing the accounting for securities transactions including complex foreign currency arbitrage transactions. Interfaced with various outside parties including the SEC and a court appointed Receiver.
• Led a team of forensic accountants in connection with an internal investigation related to revenue recognition issues at a global electronic components manufacturer. The team worked closely with counsel and the audit committee of the company and held frequent briefings with the outside auditors and the SEC.
• Led a team in a nine-month internal investigation of accounting and reporting issues at Freddie Mac, a Fortune 50 company. Work involved supervision of teams of accountants to assist counsel in conducting interviews, reviewing large volumes of electronic and paper records, and researching complex accounting issues. Made presentations to the Board of Directors, the SEC, and testified before the House Committee on Energy and Commerce.
• Analyzed various accounting issues related to cash flow hedge accounting of derivatives in the defense of a division controller of an energy trading company in anticipation of an SEC enforcement investigation.  Reviewed and commented on Wells submission to the SEC.
• Assisted in the calculation of damages related to a claim by a former officer of a public company that the company had improperly stopped him from exercising stock options. The work included researching “trading windows” and preparing a rebuttal report to the opposing expert.

Internal Investigation Support

• Led an internal investigation of potential improper payments by a large, publicly traded electric utility company. The investigation required the review of several terabytes of accounting data over a four year period within a 60-day time frame to meet SEC filing deadlines.
• Conducted an investigation on behalf of an East African governmental agency regarding an investment in a pharmaceuticals company.
• Assisted a global manufacturing company with an investigation of a jointly-owned entity involving potential improper and fraudulent use of credit card and other expenses for personal uses.
• Participated in an investigation on behalf of a large lending institution to identify instances of misleading customer statements and possible control weaknesses related to a kiting scheme.
• Coordinated and supervised a multi-year, large scale forensic accounting analyses and assisted internal and external counsel in the development of litigation claims on behalf of the Lehman Brothers Holdings Inc. bankruptcy estate. Worked as part of a larger team to maximize available assets for the benefit of the debtor’s estate and the creditors. Investigated and tracked the movement of billions of dollars of collateral between counter-parties and clearing banks in the period leading up to and through the bankruptcy filing. Interfaced with the legal and financial advisors of the unsecured creditors committee, SIPC, the Lehman Brothers broker/dealer, the court appointed Examiner, and large clearing banks.
• Retained by management of a global security software company to conduct an independent evaluation of work performed by another firm’s investigative team hired by the special litigation committee in connection with their internal investigation of stock option backdating issues.
• Performed an internal investigation on behalf of an Alaskan Native Corporation into the improper cash movements and embezzlement by a consultant to the Puerto Rico and Washington, DC government contracting operations. Identified excessive cash payments made as well as other improper vendor arrangements which resulted in a windfall being paid to the consultant.
• Conducted an internal investigation on behalf of the audit committee of a publicly traded government contracting company. Uncovered the extensive use of millions of dollars of company funds for personal use by the Chief Executive Officer. Provided information to the SEC and U.S. Attorney’s offices.
• Performed extensive accounting research and transaction analysis on behalf of a former officer of Enron. Work involved research of relevant accounting issues included special purpose entities, mark to market accounting, and hedge accounting, and the critical analysis of findings of a special investigative committee.

Anti-Bribery and Corruption/FCPA Consulting

• Conducted a review of anti-bribery and corruption controls of the Nigerian operations of one of the largest global energy companies.
• Developed an engagement with one of the world’s largest energy companies into a five-year Master Services Agreement for forensic accounting services involving anti-corruption due diligence on acquisitions.
• Won multiple FCPA pre-acquisition due diligence engagements with recurring client and law firm involving multi-billion-dollar acquisitions in Africa and Singapore.
• Conducted anti-bribery and corruption reviews and investigations for companies in various industries in Canada, Brazil, and China.
• Assisted outside counsel in an FCPA investigation initiated by whistleblower allegations involving the Latin American subsidiaries of a global pharmaceuticals manufacturer. The work involved interviews of company personnel and securing and reviewing electronic data from the subsidiary in Mexico and Chile.

Profit Disgorgement Analysis

• Provided profit disgorgement analyses for several large public companies as part of FCPA settlements with the SEC and DoJ.
• Assisted a global money services business with an ability to pay analysis as part of settlement discussions with a US government regulator which resulted in reduced payments by the company.
• Managed assignments requiring profit disgorgement analysis and ability to pay services on behalf of the DoJ and the U.K. Serious Fraud Office related to an FCPA investigation of Rolls-Royce plc.

Interim Compliance Officer

• Developed a corporate compliance function while serving as the interim Chief Compliance Officer of Control Components Inc., a $600 million global manufacturing company, facing a DoJ FCPA investigation. Developed corporate compliance policies and conducted training on compliance and FCPA issues to over 400 employees in more than eight countries including China, India, Korea, and Japan. Provided daily guidance on compliance issues and reported monthly to the Executive Directors of the UK-based parent company. 

Interim Internal Audit Resource

• Responsible for the management of the East Coast office of the Corporate Internal Audit Department of Computer Sciences Corporation, a global, Fortune 500 company, a $10 billion, publicly traded firm that provides information technology services to government and industry.
• Maintained the overall effectiveness of the office including the development and supervision of 15 internal auditors.
• Evaluated the adequacy of the system of internal controls and the consistent application of generally accepted accounting principles.
• Coordinated due diligence activities in support of corporate acquisition and outsourcing initiatives. 
• Served as team leader for acquisitions of information technology consulting companies located in the US, Australia and Italy, with annual revenues ranging from $18 million to $185 million.

Interim CFO/Project Manager

• Managed multiple, large internal investigations that required extensive planning, discussion and reporting with company senior executives, line management and board members. Quickly gained an understanding of company's structure, operations and risk profile.
• Assisted Interim CFO in reviewing language and disclosure for restated public filings with focus on potential responses by the SEC.
• Served as a NASDAQ Listing Qualifications Hearing panelist to evaluate hundreds of company's plans of compliance when faced with a delisting. Interfaced with company senior management and legal counsel from a variety of industries.

• Led an extensive board investigation related to a multi-year financial restatement of a Middle East based oil and gas company including site visits to the Kingdom of Saudi Arabia and the United Arab Emirates. 
• Conducted weekly calls with the audit committee and independent audit firms.

• Instrumental in winning two significant Independent Monitor support matters as part of FCPA deferred prosecution agreements.
• Assisted the Independent Monitor in the review and assessment of the compliance function of a global high-tech manufacturing company as part of an FCPA deferred prosecution agreement with the DoJ and the SEC.
• Evaluated the company’s system of internal controls and books and records and made recommendations for improvement. Performed on-site reviews in Singapore and China.