When we undertake international investigations, one of the first points I emphasize to clients – especially those relatively unfamiliar to global due diligence challenges – is that overseas jurisdictions simply do not have the transparency in public records that exists in the United States.

The answers – and the information – are there. But they’re hidden and, for many investigative firms, hard to uncover. This is particularly true as you move East – from South America to Eastern Europe and from the Middle East to Russia and China. One case comes to mind that exemplifies this. Our client was a diversified financial services firm with more than $70 billion in assets under management and 2,800 global employees. The firm had a robust wealth management book of business in Switzerland, currency operations in the Middle East and a keen interest in a Russian opportunity that had just surfaced. The company’s leadership team wanted to find out as much as they could about the Russian parties proposed as partners. We undertook a systematic international investigation in Russian and other languages. At the center of this effort was our need to conduct discreet inquiries with sources in North Caucasus political circles as well as the region’s oil and financial sectors. This initiative took more than four weeks. But our investigators were able to confirm that the Russian individuals were sophisticated political and industrial figures who had been tapped for key positions in the Russia State Duma. Central to our findings were the insights we collected from former KGB and Ministry of Interior employees, the subjects’ former colleagues in elite senior political and business circles, Russian journalists, political observers and media commentators. In short, we had to create the transparency the systems lacked – by systematically pulling the curtain back. The bottom line? Background investigations are not a check-the-box exercise. Especially those with an international scope. If you’re working with a new international due diligence vendor, make sure they’re capable of uncovering the information you require.

Pre-transaction due diligence: is a Google search enough?
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