Case Study – Forensic Investigation into Consulting Fees and Commission Payments for a Public Utility Company

A utility company engaged our team to conduct a forensic investigation into consulting fees and commission payments made over a three-year period. The engagement was initiated due to internal concerns regarding possible bribery and corruption involving entities in Luxembourg and France.

As part of the engagement, we conducted a detailed financial analysis of the profit and loss statements for three legal entities across both jurisdictions. This involved isolating transactions related to consultancy, commissions, gifts, and sponsorships, identifying unusual patterns or spikes in expenditure, and cross-referencing financial data with supporting documentation.

We then reviewed a wide range of materials, including invoices, consultancy agreements, CRM data, payment records, and internal and external communications, to assess the legitimacy and purpose of each transaction.

In addition, we conducted structured forensic interviews with key individuals involved in approving or overseeing the transactions. These interviews were aimed at understanding the rationale for engaging specific consultants, the procurement process followed, and awareness of any red flags at the time of contracting.

The final deliverable included:

• a forensic investigation report detailing financial flows, documentation gaps, and red flags;
• analysis of patterns indicating potential misconduct or non-compliance;
• a summary of key insights from forensic interviews;
• conclusions regarding the presence or absence of bribery and corruption indicators;
• recommendations to strengthen internal controls, approval processes, and third-party due diligence.