International Corporate Investigations One accountable case lead, local law respected in every country the facts touch

01Scope

What international corporate investigations cover

Most corporate matters that reach Delator Global start with a narrow question and grow. A finance team notices that a distributor in one country earns margins far above its peers. An anonymous message claims a regional director is steering contracts to a relative. A customs broker is invoicing for services nobody can describe. In each case the company needs facts before it decides anything: whether to discipline an employee, terminate a contract, notify an insurer, report to a regulator or simply close the file.

International corporate investigations exist to answer those questions in a way that will stand up later. That means the facts must be gathered lawfully in every country involved, documented so another reviewer can follow them, and presented without overstatement. A report that reaches the right conclusion through an unlawful interview or an improper data transfer can create more liability than the original problem.

The table below shows the main matter types Delator Global handles and where each is explained in more depth. Many engagements touch two or three of these at once, which is one reason clients prefer a single case lead who can see the whole picture.

02Service model

How Delator runs a cross-border matter

Delator Global uses a clear division of labour that has been reviewed for legal fit. International corporate investigations outside the United States are led by Delator Group consultants. The case lead builds the workplan, sets priorities with counsel, manages the budget, reviews every piece of evidence and writes or signs off the report. Consultants carry out the analytical core of the work: document and transaction review, forensic data analysis, corporate records research, open-source research, interview planning and, where the law allows, interviews of company personnel.

Some tasks are reserved by local law for licensed or registered investigators. Surveillance and background checks on individuals are the most common examples, but the list varies widely from country to country. Where a task falls into that category, a locally licensed partner in Delator's network completes it under the workplan. If the scope calls for background checks on employees or individuals, Delator leverages a locally licensed partner in its network to complete that work and does not do it itself. The partner's output comes back to the case lead, who integrates it into the overall analysis.

Traditional private investigation work abroad that sits outside a corporate matter, such as a standalone locate or a personal surveillance request, is referred to a vetted investigator within Delator's network who holds any licence the local law requires. That investigator contracts with the client directly. Cyber work is different again: digital forensics, incident response and penetration testing are carried out by Delator's own consultants and testers, and testing only proceeds under written authorization signed by the owner of the systems or premises.

• Delator consultants: scoping, workplan, document and data review, records research, interviews of company personnel where lawful, analysis and reporting
• Locally licensed partners: surveillance, background checks on individuals and any other task local law reserves for licence holders
• Referred network investigators: standalone private investigation requests abroad, contracted directly with the client
• Delator cyber team: forensics, incident response and authorized testing, always under a signed written authorization

03People

Who carries out international corporate investigations at Delator

Clients ask, reasonably, who will actually be doing the work. Delator's consultants come from backgrounds that suit cross-border fact-finding. Some served in U.S. military intelligence, where structured analysis, source evaluation and reporting under pressure are routine. Others come from the Department of Homeland Security, with experience of customs, trade, financial and transnational cases. Former law enforcement officers of many kinds bring interview discipline and an understanding of what evidence a prosecutor or court will accept. Former bail enforcement agents bring persistence and a practical sense of how people move money and themselves when they do not want to be found.

Alongside them sit technology specialists of every kind: forensic examiners, data analysts who are comfortable inside large ERP extracts, cloud and network engineers, and people who understand messaging platforms and mobile devices. On most matters the most useful insight comes from the overlap, for example an analyst who spots a pattern in vendor payments and a former investigator who knows which question to ask the accounts payable clerk about it.

The wider network holds a broad range of licences and certifications across the jurisdictions where partners operate. Delator does not present these as endorsements by any government agency, and it does not hand clients a list of acronyms in place of judgment. What matters is that the person doing each task is lawfully allowed to do it and is competent to do it well.

How a typical case team is assembled

A case team is built around the questions in the scope rather than a fixed template. A procurement fraud matter in Eastern Europe might pair the case lead with a forensic data analyst, a consultant who reads the local language and knows its commercial register, and a former law enforcement interviewer for the subject interview. A bribery matter in West Africa might add a consultant with customs and trade experience and a locally licensed partner for any background checks on intermediaries. A matter with a cyber element brings in a Delator forensic examiner from the start, so devices and cloud accounts are preserved correctly.

The case lead stays constant from intake to final report. Clients and counsel therefore have one person who knows every thread of the matter, can answer questions on short notice and is accountable for the quality of what the team produces.

04Legal frameworks

Which laws shape international corporate investigations

The law that created the problem and the law that governs the investigation are often different. A U.S. issuer looking at payments in Brazil may face exposure under the U.S. Foreign Corrupt Practices Act and Brazil's Clean Company Act, while the investigation itself must respect Brazilian labour law and data protection rules. Good international corporate investigations map both sets of rules at the start.

On the exposure side, the frameworks that most often drive corporate work include the FCPA's anti-bribery and accounting provisions, the UK Bribery Act 2010 and its section 7 offence of failing to prevent bribery, the UK Economic Crime and Corporate Transparency Act 2023 and its failure to prevent fraud offence, which took effect for large organisations on 1 September 2025, and France's Sapin II law with its compliance programme obligations. Sanctions exposure usually starts with the U.S. Treasury's Office of Foreign Assets Control and the parallel EU and UK regimes. Supply chain matters increasingly involve the Uyghur Forced Labor Prevention Act, which creates a rebuttable presumption that goods made wholly or partly in Xinjiang, or by listed entities, are made with forced labour, and the EU Forced Labour Regulation adopted in 2024, which applies from December 2027.

On the conduct side, the investigation must respect privacy and data transfer rules, employment law, criminal procedure and sometimes laws that restrict sharing information with foreign authorities. Those are discussed in the next sections because they decide how, not whether, the work gets done.

05Data and evidence

Collecting evidence lawfully across borders

Evidence collection is where cross-border work most often goes wrong. Imaging a laptop in Germany, exporting email from a Chinese subsidiary or pulling chat logs from a Brazilian sales team each raises different questions. Under the EU GDPR, the company needs a lawful basis for processing, usually legitimate interests documented through a balancing test, and the processing must be proportionate to the allegation. Data about suspected criminal offences receives extra protection under Article 10, and transfers outside the European Economic Area need a valid mechanism such as an adequacy decision, the EU-U.S. Data Privacy Framework for certified recipients, or standard contractual clauses.

Other countries have their own versions of these rules. China's Personal Information Protection Law and its data export regime can require security assessments or standard contracts before data leaves the country. Several jurisdictions have blocking statutes or sovereignty provisions. France's 1968 blocking statute restricts communicating certain information for use in foreign proceedings, and Switzerland's Criminal Code, in Article 271, penalises carrying out acts on Swiss soil on behalf of a foreign state without authorization. These rules do not always prevent an investigation, but they shape where data is reviewed, who reviews it and what leaves the country.

Delator's approach is to agree a data plan with counsel before collection starts. Often the answer is to review data in the country, with only relevant, minimized material exported, or to use a regional review location. Forensic collection follows documented procedures consistent with ISO/IEC 27037 guidance on the identification, collection, acquisition and preservation of digital evidence, with hash verification and a chain-of-custody record for every item.

• Map where relevant data physically sits and which entity controls it
• Confirm lawful basis, works council or employee notice obligations and transfer mechanisms
• Collect forensically with hash values recorded at acquisition
• Review in-country where required and export only what the matter needs
• Keep a single evidence register that ties each finding to its source

06Privilege

Working through counsel and protecting privilege

Most clients engage Delator Global through outside counsel or the legal department. This is not a formality. In the United States, work performed at the direction of counsel to help counsel give legal advice can be protected by attorney-client privilege and the work product doctrine. Company lawyers usually give interviewees an Upjohn warning explaining that counsel represents the company, not the individual, and that the company controls the privilege.

Privilege does not travel neatly. English law distinguishes legal advice privilege from litigation privilege, and the Court of Appeal's 2018 decision in SFO v ENRC clarified when litigation privilege can attach to internal investigation material. In EU competition proceedings, the Court of Justice confirmed in Akzo Nobel in 2010 that communications with in-house lawyers are not privileged. Many civil law countries recognize professional secrecy for outside lawyers but treat investigator notes very differently. Delator structures its engagement letters, communications and drafts so that counsel's strategy is protected as far as each jurisdiction allows, and it flags early where protection is likely to be weak.

Practically, that means drafts go to counsel first, interview memoranda are written as summaries for counsel rather than verbatim transcripts unless counsel asks otherwise, and factual findings are separated from legal conclusions. Delator is not a law firm and does not give legal advice; the consultants' job is to give counsel the facts in a form counsel can rely on.

07Interviews

Interviewing employees and witnesses in other countries

Interviews are usually the most revealing step in international corporate investigations and the one most exposed to local law. In Germany, a works council may have co-determination rights over certain monitoring and investigative measures, and employees may be entitled to have a council member present. In France, employee representatives and the duty of loyalty in the employment relationship affect how interviews are conducted. In several Latin American and Asian jurisdictions, labour courts look closely at any interview that could be described as coercive. Employment contracts and company policies may also give the employee rights the investigator must honour.

Delator plans interview sequences with counsel. Typically, peripheral witnesses who can explain processes are seen first, then people closer to the transactions, and the subject of the allegation last, once documents have been reviewed and the questions are precise. Interviews are conducted in the interviewee's language where possible, using vetted interpreters who sign confidentiality undertakings. Interviewers explain who they are, who they act for and how the information will be used.

Interviews of people outside the company, such as former employees, suppliers or competitors, require more care. Where those contacts amount to work local law reserves for licensed investigators, a locally licensed partner in Delator's network carries them out. Delator does not approach government officials in connection with a bribery matter, and it does not use pretexts that would be unlawful in the jurisdiction.

08Records research

Corporate records, ownership and open-source research abroad

A large share of the work in international corporate investigations is records research: who incorporated a vendor, who its directors are, whether it files accounts, which court cases name it and what local media have reported. The quality of public records varies enormously. The UK's Companies House register and people with significant control register are open and searchable, though reforms under the 2023 Act are aimed at improving the reliability of what is filed. Many EU member states restricted public access to their beneficial ownership registers after the Court of Justice's November 2022 ruling that unrestricted public access interfered with privacy rights. Some offshore jurisdictions disclose very little at all.

Delator consultants work in local languages and know where each country keeps the useful records: commercial registers, gazettes, land registries, procurement portals, court dockets, insolvency notices and regulatory enforcement databases. Open-source research extends to local news archives, trade press, social media and archived web pages, always within the law and the platforms' terms. The aim is not to produce a thick file but to answer specific questions, such as whether the vendor's registered address is a residential flat, or whether its sole director also works in the client's procurement department.

Where the question becomes a background check on an identified individual, the work moves to a locally licensed partner in Delator's network. That boundary protects the client as much as it protects Delator, because some countries treat personal background research by unlicensed parties as a regulatory or criminal matter.

09Hard jurisdictions

Countries where investigations are harder, and what that means

Some jurisdictions make investigative work difficult. China is the clearest example. Its data export rules, the counter-espionage law as revised in 2023 and high-profile enforcement against foreign consulting and due diligence firms in that year mean that work touching mainland China needs very careful scoping, local counsel input and, often, a more limited set of methods than clients expect. Other countries restrict access to records, regulate investigators tightly or make it risky for local staff to cooperate. Within some federal systems, individual states or provinces apply stricter licensing rules than their neighbours.

Difficulty does not always mean impossibility. It usually means changing the method: relying more on data the company already holds, reviewing material in-country, working through counsel's local network, accepting that some questions cannot be answered and saying so clearly in the report. Delator will answer any question about a specific country before you commit to an engagement, including whether the matter is realistic at all.

Delator does not take work in countries subject to comprehensive U.S. sanctions, and it declines engagements where the only way to get the answer would be to break local law.

10Engagement

Scoping, budget and timelines for international corporate investigations

Every matter begins with a scoping call, usually with counsel present. Delator wants to know the allegation or concern, who already knows about it, what has been preserved, which countries and entities are involved, what decisions the client needs to make and by when. A conflicts check follows. Delator then proposes a written scope that sets out the questions to be answered, the methods, the people involved, which tasks a locally licensed partner will handle, the reporting points and a budget estimate built from those components.

Timelines depend on the volume of data, the number of countries and the availability of witnesses. A focused inquiry into a single vendor or employee often runs two to six weeks. A multi-country review of third-party payments commonly runs several months, with interim briefings so the client is never waiting for a single final document. These are typical ranges, not promises, and the scope states the assumptions behind them.

Budgets stay controlled through phasing. Phase one usually tests the allegation quickly with the data closest to hand. If it is not substantiated, the matter can close with a short memorandum. If it is, phase two broadens the review with the client's agreement. This keeps cost proportionate to risk, which regulators also expect when they assess how a company responded.

11Early mistakes

Mistakes that weaken international corporate investigations before they start

Many of the problems Delator sees in international corporate investigations were created in the first few days, before any outside help arrived. A well-meaning regional manager confronts the suspected employee, who then wipes a phone. An IT administrator forwards a mailbox to headquarters without considering local privacy law. A finance director quietly asks the vendor for an explanation, and the vendor's records are tidied overnight. None of these steps is malicious, and all of them make the eventual findings weaker.

The second common mistake is defining the question too broadly or too narrowly. 'Find out everything about the Mexico office' produces a large bill and an unfocused report. 'Check whether invoice 4471 was paid twice' may miss the pattern of which that invoice is one small part. A good scope names the specific allegations, the period, the entities and the people, and then states what would justify widening the inquiry.

The third mistake is choosing investigators by convenience. The company's own auditors may be conflicted if the conduct touches areas they signed off. Local staff may know the subject socially. A firm in one country may have no lawful way to work in another. Independence, competence and legal fit in every country involved matter more than speed of appointment, and they are the qualities a regulator or court will ask about later.

• Do not confront the subject or the counterparty before evidence is preserved
• Do not move data across borders until the transfer basis is confirmed
• Limit knowledge of the matter to a small, named group
• Write down what has already been done, by whom and when
• Check insurance policies for notice requirements and deadlines

12Outcomes

What happens after the findings

A report is only useful if it supports a decision. Delator's reports state the questions asked, the work done, the facts found, the level of confidence in each finding and the limits of the inquiry. Findings are tied to exhibits through the evidence register, so counsel can test any statement. Where relevant, the report includes control observations: the specific weaknesses that allowed the conduct, written plainly enough for finance and operations teams to act on.

What comes next is the client's decision with counsel's advice. Common outcomes include employment action, termination of a third-party relationship, an insurance claim under a crime or fidelity policy, civil recovery proceedings, a criminal complaint in the local jurisdiction or a voluntary self-disclosure to a regulator. Each outcome has its own evidential needs, and Delator can support the next step, from preparing a proof of loss to tracing assets for recovery to giving a factual account of the work if the matter is litigated.

Remediation is where many companies lose momentum. Delator can return after an agreed period to test whether the control changes were made and are working, which is the kind of evidence enforcement authorities look for when they evaluate a compliance programme.

• Employment and disciplinary decisions grounded in documented facts
• Exit or renegotiation of third-party relationships
• Insurance notifications and proof of loss support
• Civil recovery and asset tracing
• Regulatory self-disclosure decisions made by counsel with a complete record
• Control remediation and follow-up testing

Step by step

How an Engagement Works

1. 01

   Confidential intake

   A scoping call with you and counsel to understand the concern, the countries involved and the decisions ahead.

2. 02

   Preservation

   Immediate advice on legal holds, device and data preservation and avoiding tipping off the people involved.

3. 03

   Written scope

   A signed scope sets out questions, methods, partner tasks, reporting points and a phased budget.

4. 04

   Collection and review

   Documents, data and records are collected lawfully, logged and reviewed by Delator consultants.

5. 05

   Partner tasks

   Any work local law reserves for licence holders is completed by a locally licensed partner in Delator's network.

6. 06

   Interviews

   Planned interview sequences with counsel, in the interviewee's language, respecting local employment rules.

7. 07

   Reporting

   Interim briefings and a final report with findings, confidence levels, exhibits and control observations.

8. 08

   Follow-through

   Support for recovery, insurance, litigation or remediation testing as the client decides.

Deliverables

What You Receive

• Written scope and phased workplan agreed with counsel
• Data protection and collection plan for each country involved
• Evidence register with chain-of-custody records and hash values for digital items
• Chronology of key events and transactions
• Interview summaries prepared for counsel
• Corporate records and ownership findings for relevant entities
• Interim briefing notes at agreed milestones
• Final report with findings, confidence levels and limits of the inquiry
• Control observations and remediation points for finance and operations teams

Industries

Who Uses Corporate investigations Services

• ManufacturingMulti-country plants, distributors and procurement create room for kickbacks, diversion and inventory loss.
• Energy and natural resourcesLicences, concessions and government touchpoints raise bribery and third-party risk.
• Life sciences and healthcareInteractions with publicly employed doctors and hospital procurement are a long-standing enforcement focus.
• Technology and softwareReseller channels, trade secrets and export controls all generate cross-border inquiries.
• Financial servicesRegulators expect fast, documented investigations of misconduct, fraud and sanctions breaches.
• Logistics and shippingCustoms brokers, freight forwarders and port agents sit at frequent points of corruption and diversion.
• Private equity and investorsPortfolio companies abroad need independent fact-finding when problems surface after a deal.
• Consumer brands and retailCounterfeits, grey market goods and supplier labour practices affect revenue and reputation.

Credentials

Who Does the Work

Delator Global's consultants come from backgrounds where finding facts under pressure is the job: U.S. military intelligence, the Department of Homeland Security, former law enforcement officers of every kind, former bounty hunters, and technology specialists across networks, applications, forensics and data. Behind them sits a network of locally licensed partners holding a wide range of licences and certifications, so every part of an engagement is done by someone entitled to do it in that country.

• Military intelligenceCollection planning, analysis and reporting discipline.
• Homeland securityFederal investigative and border, trade and financial crime experience.
• Law enforcementInterviewing, evidence handling and courtroom testimony.
• Bail enforcementLocating people who do not want to be found, lawfully.
• TechnologyNetwork, application, cloud and forensic specialists.
• Licensed partnersLocal licences for the work local law reserves.

Related services

Related Delator Global Services

• CorporateInternational Fraud InvestigationsFraud inside a multinational usually hides in ordinary transactions: a vendor that looks legitimate, an expense claim that is slightly too round, a payroll record for someone nobody has met.
• CorporateAnti-Bribery and Corruption InvestigationsA suspicious commission to a customs agent, a consultant paid through a third country, a hospitality budget that keeps growing near a tender deadline: these are the facts that start anti-bribery and corruption investigations.
• CorporateInternational Due DiligenceInternational due diligence answers a simple question that is hard to answer well: who is really on the other side of this deal, and what will we inherit if we sign? Delator Group consultants lead the work for legal, compliance and deal teams, scoping each review to the risk, the jurisdiction and the decision it has to support.
• CorporateInsider Threat InvestigationsInsider threat investigations examine what happens when someone with legitimate access, an employee, contractor, partner or former staff member, uses it to take data, steal trade secrets, commit fraud or cause harm.
• CorporateSupply Chain and Sanctions InvestigationsSupply chain and sanctions investigations answer questions regulators now expect companies to answer with evidence rather than assurances: who made the goods you import, who ultimately owns the parties you deal with, and where your products end up after they leave your hands.

Every Delator Global service

Countries

Where Delator Global Works

Delator Global handles matters in 152 countries, with a country page for each and a city page for every city over 200,000 people. Larger markets are listed below; the full list is on the international page.

• United Kingdom
• Canada
• Mexico
• Germany
• France
• India
• Brazil
• Australia
• Japan
• United Arab Emirates
• South Africa
• Nigeria
• China
• South Korea
• Spain
• Italy
• Netherlands
• Poland
• Turkey
• Philippines
• All 152 countries