Case Study
FTI Technology Delivers Rapid Response, Critical Fact Finding and Defensible Reduction of More Than 10 Million Documents in Multi-National Financial Services Regulatory Investigation
A large, global bank was facing multiple regulatory inquiries into certain practices, which required the organization to conduct an in-depth investigation across jurisdictions. FTI Technology was engaged to provide digital forensics, data processing, project management and managed document review services across the entire matter.
Situation
The matter spanned multiple, cross-continental regulatory agencies. Given the nature of the investigation, large volumes of documents and information from complex data sources were in scope. Additionally, the documents contained information and communication in 11 different languages, including English and a lesscommon European language, requiring select document reviewers with both financial industry experience and specialized language fluency.
The concurrent investigations required defensible collection of current and historical data from multiple non-traditional sources, for specific periods of time. The client’s organisation had many systems in place across different functions of the business, all which needed to be evaluated and potentially preserved for relevance to the matter. Doing so required a lengthy exercise of identifying the right people within the institution who had the knowledge to guide the investigatory team to the right data sources effectively and efficiently.
The initial digital forensics, collection and processing exercises for the investigation resulted in a set of 14 million documents that would need to be reviewed for the matter. Findings following the review would be presented to numerous authorities.
Our Role
FTI Technology brought the full force of its Disputes & Investigations capabilities to support the client in this matter. Once a clear understanding of the target data sources — which spanned communications platforms, regulated chat applications and information from financial systems — was established, digital forensics experts conducted data preservation, collection and processing. The team then established workflows to enable visualisation and review of all the different forms of structured and unstructured data simultaneously in one platform.
In addition to providing digital forensics and e-discovery specialists to handle evidence preservation, collection and data processing, FTI Technology’s Acuity team provided project management and managed document review to help the client execute review efficiently, defensibly and within the timeframes required by regulators.
The review team provided the following:
- A diverse pool of document reviewers readily available to provide a breadth of expertise across multiple industry and regulatory nuances, as well as language capabilities. FTI Technology presented high calibre document review candidates to the client for individual interview and selection, to reinforce confidence in the quality and experience of the broader team.
- Retained elite multi-lingual reviewers for the duration of a complex and lengthy project with multiple review cycles.
- Unique expertise with emerging data sources and uncommon formats to ensure all potentially relevant information could be properly addressed.
- Expert consultation ahead of project kick-off and throughout the project life cycle. FTI Technology’s team flagged potential drawbacks of the document coding initially requested early on and recommended additional coding tags to prevent downstream issues,improve efficiency for the client’s second level review, and achieve a critical mass of documents reviewed ahead of meetings with regulators.
- Robust quality assurance methodologies to discover additional types of documents to cull from the review population, including 100,000 documents from the Bloomberg Chat platform.
Our Impact
- Ultimately, a thorough and defensible investigation was completed, with a critical mass of documents reviewed in advance of the client’s deadline to present findings to regulatory agencies.
- FTI Technology reduced the document population from 14 million to approximately 200,000 documents for review. Key to this 98.5% reduction was a result of highly relevant documents the team located throughout the review, which helped to focus the discovery of additional relevant documents.
- Through the team’s unique, expert-led approach, pivotal documents were found within the first 72 hours of review, providing the client with a roadmap of additional custodians and types of data to investigate for additional documents of high importance.
- Review workflows and quality assurance checks provided further reduction of the document set, providing time and cost savings.