We counsel clients under the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws, while defending investigations, advising on cross-border transactions and assisting in the creation of robust compliance and business ethics programs for client organizations. We have supported international companies to meet their obligations under the FCPA, UK Bribery Act, OECD Anti – Bribery Convention and the UN Convention Against Corruption, as well as to ensure compliance with the Nigerian Financial Crimes and Anti-corruption laws. One of our competence lies in the delivery of end-to-end system development and improvement assignments. We undertake risk assessments, including corruption risk assessments (CRA), development of mitigation measures, sometimes in the form of integrity plans. We undertake system reviews and studies as well as mapping and scoping of integrity initiatives for government and businesses. We also develop and deliver related capacity building and learning programs.

Our personnel have experience developing national methodology, and undertaking sectoral corruption risk analysis and plans to improve system integrity for governments at sub-national and national levels. Our experience undertaking such assignments spans the education, health, water sectors and Port sector. Report of the 2013 Risk Assessment in the Nigerian Port Sector which our personnel led can be found at http://tugar.org.ng/publications/.  Both in the public and private sector, we help organizations better understand the risks that bad behavior will occur and to plan and deploy measures to prevent such occurrences, or to detect early, if and when they occur and manage the consequences and associated outcomes.  Our focus is to protect organizational systems and the institutions; our support aims first to prevent infractions and secondly to prepare the organization to best protect itself in the rare occasion that an infraction occurs.

In addition to system studies, diagnosis and development of mitigation measures, we support implementation of devised measures and plans. We hold the clients hands until the desired

outcome is achieved, for example we have led the Implementation of the three Prioritized Objectives from the Nigerian Port Sector Corruption Risk Assessment (CRA) Integrity Plan, including developing anti- corruption policies and putting in place standard operating procedures and sector complaint management mechanisms for Port sector stakeholders in Nigeria see www.pssp.gov.ng. We have had the experience of supporting the full circle from diagnosis, to design and implementation of mitigation measures in  important projects.

Where incidents have occurred, we support clients to do any or all of the following; undertake internal investigations to determine what went wrong; evaluate levels of system resistance to breaches and test efficacy of existing prevention and detection mechanisms; evaluate organizational and individual responsibility and evaluate risk of organizational culpability; prepare remediation measures and help clients manage regulatory fallouts if any. We have in some instances along with others undertaken similar assignments to defend FCPA investigations and proceedings, and at other times we have worked in teams supporting FCPA adversary proceedings against potentially infringing target companies in-country and externally including publicly quoted companies in such jurisdictions as the United States and many times regarding their operations in Africa.

Our experience has included helping the Nigerian government at national and regional levels to map existing anti-corruption and governance measures in Public Finance Management, studies that evaluated initiatives at the National level and in 26 sub-national governments in Nigeria including the pioneer compliance study evaluating compliance of anti-corruption  laws, and initiatives at the National and in the states in Nigeria with United Nations Convention Against Corruption, African Union Convention on Preventing and Combating of Corruption Economic Community of West African States Protocol on the Fight against Corruption. This was the first three level compliance study of its kind conducted in Africa. These reports can be found at http://tugar.org.ng/publications/ .