Multinational Industrial Company

A multinational US industrial company was conducting due diligence in the possible acquisition of a US company whose German subsidiary had an extensive international sales network. When general inquiries revealed a risk of improper payments and possible OFAC/sanctions issues, the company retained O’Melveny to review the target’s business model and compliance structure to identify the extent of the risks. An O’Melveny team interviewed senior management and the sales and financial controls staff in Germany, reviewed financial records pertaining to sales, agents, and promotional activities, and provided advice on structuring the transaction and revising the target’s compliance policies and procedures.