Colin Flood

Colin’s professional experience includes:

Government and Internal Investigations

• Bribery and Corruption: Led teams of forensic accountants to investigate alleged FCPA violations by a U.S.-based global manufacturer related to business conduct in Europe, Africa, the Middle East, and Asia. Presented findings to the SEC, DOJ, and FBI. Further assisted the company in developing and implementing global remedial actions, including enhancements to compliance procedures and internal controls following enforcement action and a substantial fine by U.S. regulators.
• Financial Reporting and Accounting Fraud: Investigated alleged improper accounting practices involving a multi-year expense management scheme for a global organization. Worked with counsel in response to an SEC subpoena and related inquiries; led a team of forensic accountants to perform financial analysis; provided advice on technical accounting requirements; and translated investigative findings into terminology understood by both counsel and management. The company settled with the SEC and restated multiple years of financial statements.
• Trade Sanctions: Investigated concerns regarding sales to a sanctioned country by a U.S.-based multi-national corporation. Led a team of forensic accountants and technologists to analyze financial records and electronically stored information and assisted counsel with interviews in the Middle East. Findings and procedures were disclosed to the Office of Foreign Assets Control and the U.S. Department of Commerce.
• Fraud and Misconduct: Assisted outside counsel of a global technology company investigate allegations of travel and entertainment fraud and corruption in China. Procedures included forensic data analytics, detailed transaction analysis, review of email and electronically stored information, and interviews of local management.
• Revenue Recognition: Assisted outside counsel with an investigation into channel stuffing and bill-and-hold arrangements in Russia. Analyzed financial records, conducted interviews of local management, and provided advice on the application of accounting standards with respect to the issues identified.
• Procurement Fraud: Investigated alleged conflicts of interest and procurement fraud in China for a global consumer products company. Procedures included electronic data analysis for 100+ employees, visits to suspect third-party locations, and analysis of intellectual property data to assess potential fraud.
• Cyber Fraud: Investigated a cyber fraud perpetrated against a CFO and the treasury department that resulted in funds diverted to offshore accounts. Utilized investigation strategies and tools to perform detailed financial analysis; drew conclusions from the analysis and reported results to counsel and management.
• Corrupt and Fraudulent Practices: Assisted the government of an African country with an investigation into allegations of public corruption, fraud, waste, and abuse. Procedures included interviews with government ministries, analysis of the country’s public finances, and IMF reporting processes.

Corporate Governance and Regulatory Compliance Matters

• Global Compliance Program Evaluation: Led an assessment of a Fortune 50 company’s global ethics and compliance program based on Federal Sentencing standards, DOJ guidance, and leading practices. Interviewed company personnel including the Chair of the Audit Committee, CEO, and other senior management.
• Anti-Corruption Compliance Monitoring: Led numerous engagements to assist a global conglomerate owning multi-national organizations operating in a diverse range of sectors and markets to develop and implement anti-corruption compliance procedures and perform compliance monitoring audits for at-risk subsidiary locations.
• Transaction Due-Diligence: Conducted anti-corruption due diligence of target entities for various Fortune 500 companies contemplating foreign acquisitions. Performed due diligence procedures across different countries and multiple industries, including manufacturing, healthcare, and financial services.
• Risk Assessments: Conducted fraud and bribery/corruption risk assessments for global organizations. Activities included identifying inherent fraud and corruption risk areas at global and regional levels for the prioritization of monitoring activities and identifying improvement opportunities in the existing control environment.
• Compliance Data Analytics: Advised and supported global organizations with the implementation and deployment of forensic data analytics utilizing technology to enable risk-based compliance monitoring.