Assessing the Adequacy of a European Anti-Corruption Agency Investigation: An iSanctuary Expert Review.

Acting for a private client, iSanctuary was commissioned to review a criminal investigation undertaken by a European anti-corruption agency following allegations of corruption, made by our client, against government officials in a position of influence for regulating the client’s business, a regulated financial institution. We were required to review voluminous amounts of investigative material and prepare an expert witness statement for service in civil proceedings, all within a noticeably brief time limit. We reviewed the material, which was not in the English language, and took into consideration both the regulatory framework and criminal investigation regime within the country in question. We were able to provide a comprehensive and detailed report, highlighting our expectations as to what an investigation (into allegations of state-level corruption) should cover as a bare minimum, highlighted specific areas where the investigation was assessed to be deficient, in terms of scope, and accentuated lines of enquiry that should have been considered and/or followed up.