Senior VP Risk Solutions & InvestigationsWashington, DC 2008 to date Partner Marlin Global Holdings, Washington, DC 2005 to 2008 Managing Director Diligence/Citigate Global Intelligence 2003 to 2005 Senior VP Control Risks Group, Washington, DC. 2000 to 2003 Director PricewaterhouseCoopers, Washington, DC. 1997 to 2000 VP The Investigative Group, Washington, DC. 1989 to 1997 Investigator U.S. Securities and Exchange Commission, DC1981 to 1989
Corruption and FCPA Cases
- On behalf of the World Bank, I directed international investigations into allegations regarding possible kickbacks, embezzlement and conflicts of interest. Inquiries were pursued both domestically and internationally. These investigations were part of this client’s global anti-corruption initiative. Based on investigative findings, I helped design and implement a program to prevent corruption by supporting competitive, efficient and accountable markets; manage external corruption through mechanisms to identify, prevent and respond to corruption on both a programmatic and case-by-case basis; manage internal corruption utilizing, communication, training and compliance programs to assure adherence to the highest ethical standards.
- On behalf of a sovereign government, I was part of an in-country team that conducted corruption investigations of a past administration. We investigated major government funded projects including the construction of the airport and the repaving of highways and roads. Based on findings, the government recovered millions of dollars.
- On behalf of the board of directors and through counsel, I conducted an investigation of questionable payments by corporate officials to foreign entities. I identified payments to third parties that appeared to function as nominees for relevant government officials. As part of this inquiry investigative steps were conducted in five Asian countries, two countries in the Middle East and the United States. At the direction of management, the client withdrew from the bidding process.
- On behalf of counsel, I investigated payments made by local employees of a company to a foreign government agency in an Eastern European country. The company was in the process of bidding for a government contract. I determined that the government agency awarding the contract was also involved with issuing shipping and transportation permits. The local employees made routine payments for permits to transport materials by truck. The client concluded these were facilitating payments and continued with the biding process.
- As a Market Surveillance Specialist in the Division of Enforcement, I worked for two years on the main Drexel investigation. I worked with a team of attorneys investigating allegations of insider trading, manipulation and fraud. During the case, I reviewed thousands of documents including trading records, deal documents, internal memorandum and other Drexel intra-company communications and analyzed trading in equities, bonds and options. As part of the case, I took testimony from many witnesses. I prepared final case memoranda as well as weekly summaries.
- On behalf of a special committee of the board of directors of an international corporation, I investigated the sale of structured financial products to the company by an investment bank. The client sought to reduce exposure to fluctuations in the exchange rates of several currencies. The investigation found that corporate executives responsible for the investment decisions had no expertise in structured products and relied exclusively on representations by the investment bankers. The structured products substantially increased the client’s risk from currency fluctuations. A negotiated settlement was reached.
- On behalf of counsel, I conducted a forensic analysis of trading and financial documents in a major securities case before the SEC and the Justice Department. I reviewed and analyzed hundreds of account statements, trading blotters, order tickets, confirmation statements and other trading related materials. I met with law enforcement officials on a regular basis as the client became a cooperating witness.
- On behalf of an international hotel management company, I conducted pre-deal due diligence of a potential joint venture partner in Macao. After finding no issues from publicly available information, I continued the inquiry by gathering intelligence from international sources. Although the potential partner was as a highly successful hotelier and shipper, he was also known for his ties to illegal gaming. Whereas this actually enhanced his reputation in parts of Asian culture, this was an issue for the U.S.-based client.
- On behalf of a major private equity fund, I conducted due diligence of a potential $50 million investment in a Mexican gaming company. After gathering public documentation, analyzing internal records, gathering intelligence and conducting dozens of interviews, I determined the three individuals listed on the gaming license were nominees. Although not listed on corporate records, a husband and wife were identified as the de facto CEO and COO, respectively, and critical to the success of the venture. Further investigation revealed the husband, who had dual citizenship, had fled the United States twenty years ago to escape drug and fraud charges.
- On behalf of a group of investors, I conducted pre-investment due diligence of the founder of a fund seeking to raise capital. Although the individual had an apparent record of success, there were numerous civil law suits against him. Interviews and additional analysis revealed questionable business practices and several unsatisfied investors. Based on this analysis, the investors declined. Several years later, the fund manager was charged with operating Ponzi scheme.
Tufts University - BA in Economics 1973 to 1977
Boston University - MBA in Finance1979 to 1981