Agility in Cross-Border Response to SEC & DOJ Investigations for Global Energy Company

A global oil services company is involved in a joint U.S. Securities and Exchange Commission (SEC) and Department of Justice (DOJ) investigation spanning both the U.S. and U.K. Tight timelines, specialized data handling, and a cross-border review required agility and high levels of coordination to minimize risk & cost.

An existing pre-negotiated and approved Master Services Agreement (MSA) allowed Consilio teams to quickly engage on the matter to understand the client’s requirements.

Identifying the need for cross-border support, two workspaces and two project teams were established under the leadership of seasoned project managers based in the U.K. and U.S.

Consilio Data Operations teams rapidly engaged to understand the scope of data / processes involved. Given the sensitive nature of the client’s work, the client utilized encryption-at-rest with nearly all data. Consilio experts worked with the client to un-encrypt data with zero loss.

A modified Immediate Case Assessment (ICA) process was then employed to uncover additional insights from the data set. Techniques included search term analysis, email threading, date culling / filtering, and more, in coordination with all teams including outside counsel.

In response to the SEC subpeona, two review teams were established, one in the US and one in the UK, to perform custodian interviews and subsequent first level review for relevance. As the project progressed, the client consolidated all review with Consilio in the UK.

Cross-border project teams’ tight coordination ensured that both strategies employed and project execution were uniform and consistent. With a depth of expertise and flexible workflows, Consilio adjusted to meet Outside Counsel’s preferences.

Consilio assisted in the production of sixteen volumes (approximately 34,000 documents) to the Securities and Exchange Commission and six volumes to the Department of Justice from the U.S. workspace.

Demonstrating agility and tight coordination to meet project requirements, Consilio has been retained at both OSC’s recommendation and the client’s approval on additional cross-border matters.