Practice Areas

Expertise that has been honed over 40 years.

Forensic Fraud Investigations

Individuals, organizations, and their counsel often turn to outside forensic examiners to answer concerns around financial statement fraud, asset misappropriation, corruption and bribery. False entries, embezzlement, misappropriation of assets, bribery, bid rigging, illicit kickbacks, and other frauds can introduce significant risk of regulatory sanction and reputational harm to businesses.

Families can be forever damaged and relationships destroyed in disputes over inheritances and estates. Corrupt caretakers, advance fee thieves, and romance swindlers can wipe out a retiree's life savings.

With deep experience in investigations, FLC will quickly assemble a core audit team and develop an investigative strategy designed to identify documentary and digital evidence, internal and external sources of relevant data, and logical witness interviews.

We approach every investigation with a singular driving purpose – to resolve the issues as thoroughly, effectively, and timely as possible, with the fewest persons required, in the least intrusive manner to the client.

Secondarily, and no less important, is an objective to determine the root cause of the event and point attention to control environment deficiencies exploited as part of the case.

FLC’s investigative team comprises former FBI senior executives and managers, corporate security and fraud executives, and computer forensic specialists and intelligence analysts, among others. FLC’s investigations are led by its senior principal who brings forty years of experience to forensic accounting and internal/occupational fraud investigations.

Areas of expertise involve investigations surrounding:

Corruption, including conflicts of interest, purchasing schemes, sales schemes, bribery, bid rigging, kickback schemes, illegal gratuities, economic extortion, self-dealing and undisclosed relationships
Asset Misappropriation, including embezzlement, skimming and account receivable lapping, and write-off schemes; fraudulent disbursements resulting from billing schemes, payroll and expense reimbursement schemes; check tampering and other unauthorized transactions
Financial Statement Fraud involving net worth/net income understatement schemes tied to timing differences, overstated liabilities and expenses, improper asset valuations, etc.; and net worth/income overstatement schemes involving fictitious revenues, understated expenses, and concealed liabilities
Identity Theft, Title Theft, Credit and Debit Card Fraud
Business Email Compromise (BEC) frauds, family-owned business disputes, estate and inheritance disputes, bankruptcy fraud, trustee abuse/fraud, senior and elder financial abuse, commercial and personal loan origination fraud, PPP loan fraud, construction loan fraud, floor planning schemes, etc.
Whistleblower, integrity and ethics hotline, and anonymous allegations

Sensitive Employment and EEO Investigations

Investigations into employee misconduct, especially so involving senior corporate executives, are among the most sensitive of internal inquiries. Allegations of sexual harassment, hostile work environment, and discrimination in the workplace must be addressed promptly through a thorough investigation, often involving a team of outside counsel, forensic examiners, and other skilled disciplines.

As an FBI Inspector, FLC’s principal led sensitive criminal and administrative investigations into FBI employee misconduct allegations in partnership with the FBI Office of Professional Responsibility and the Department of Justice - Office of Inspector General.

As a corporate senior fraud executive, he teamed with internal and outside counsel in delicate ethics and equal employment opportunity investigations, including document and data discovery and analysis, coordination of computer forensic analysis, open-source intelligence analysis, witness interviews, and reporting. He also supported the defense and prosecution of attendant litigation.

In both his public and private experience, FLC's principal testified before federal grand juries, in state and federal district court, at arbitration hearings, and before U.S. Senate committees / sub-committees.

Areas of expertise in employee investigations include:

Allegations of workplace discrimination, including sexual harassment, hostile work environment, and race, age, and gender-based discriminatory employment actions, including allegations of retaliation and reprisal
Code of Ethics, fair treatment in the workplace, professional conduct, abuse of authority, and other violations of corporate policy governing employee conduct in the workplace
Compliance related allegations, including failure to disclose criminal, financial, and ethical matters required of licensed employees by regulatory agencies, e.g., FINRA and the SEC

Fraud Risk Management Program Governance

In 2016, the Committee of Sponsoring Organizations of the Treadway Commission (COSO) released its Fraud Risk Management Guide as a framework for organizations to follow in addressing the risk of fraud to operations. The Guide builds upon the 2013 COSO Internal Control - Integrated Framework, recognized as a leading global framework for designing, implementing, and operating internal controls and assessing their effectiveness.

The 2016 Fraud Risk Management Guide is considered by many fraud, audit, and risk specialists to be the standard against which organizations should measure their Fraud Risk Management Programs (FRMP), including:

Establishing fraud risk governance policies and procedures
Performing an enterprise-wide fraud risk assessment
Designing and deploying fraud preventive and detective control activities
Conducting investigations, and
Monitoring and evaluating the total fraud risk management program

The Guide contains principles and

points of focus highlighting fundamental concepts of internal control and their underlying important characteristics. The Guide's five principles are consistent with the five COSO Internal Control Components and the 17 COSO principles.

FLC's principal is deeply skilled in fraud risk management, fraud governance, investigations, fraud monitoring, and in facilitating internal and external assessments of an organization's FRMP against the COSO Fraud Risk Management Guide. He has led both internal and external (independent) assessments of an organization's FRMP.

He has also led comprehensive fraud risk assessments across a global enterprise, leading to findings around division and sub-division risk appetite, residual risk, and controls deficiencies, with recommended action plans designed to bring residual risk in line with the organization's risk appetite.

As Vanguard's senior fraud executive responsible for protecting over $5.1 trillion in client assets, FLC's principal led the development and execution of its enterprise fraud prevention, detection, and response defenses, including its web threat detection and big-data solutions. He was also instrumental in devising and improving the organization's client channel authentication strategies - web, mobile, phone, and mail, in concert with its Client Channel Security Strategies team.

FLC's principal presented often on Vanguard's fraud and authentication controls before the SEC, FINRA, the OCC, the PA Department of Banking, major Institutional clients and prospects, as well as Retail ultra-high net worth clients and personal business home offices. He was considered Vanguard's single voice of authority on internal / external fraud and physical and personnel security.