The Chemical Scandal That Touched the Shadows

Internal fraud starts small but connects quickly to organized crime
An HR scheme can escalate into chains of trafficking, prostitution, and international laundering, exposing the company to existential risks.

Case Study: The Chemical Multinational Company and the Invisible Risk

Every serious investigation begins with a simple question: What is the customer's real problem? It's not always the fraud. It's not always the money. Most of the time, it's the invisible risk that no one wants to name.

This case involved a European chemical multinational about to face a hostile takeover. A scandal at any subsidiary — especially in Brazil — could destroy the business. When I arrived at the company's office in Rio de Janeiro, I found a tense scenario: the global director of corporate risk, confused internal auditing, and a number that circulated as a diagnosis — US$ 15 million embezzled.

It's just that the director's fury wasn't over the blunder. That was why the gap represented:

• serious governance flaws,
• external auditors who “didn't see anything”,
• and the real threat: the involvement of a third party connected to criminal organizations.

The discovery of the common thread

The internal scheme was relatively simple: HR employees former employees were “resurrecting”, processed undue payments and divided the amounts between the group and the third operator.

What nobody wanted to believe was what came next. The third used the resources to buy cocaine from drug dealers, supply prostitution rings in nightclubs in Copacabana, and distribute drugs to oil platforms in Macaé. The money, then, was laundered by means of a Swiss bank, already at values much higher than the deviation.

Suddenly, we were no longer faced with an internal fraud.
We were faced with a systemic criminal risk, with international ramifications and the potential to devastate the company's reputation.

The local council wanted police. Not me.

The legal firm hired by the multinational insisted on the classic protocol:

• register occurrence,
• call on authorities,
• move processes.

It was a mistake. It's serious.

The third - the scheme's operator - knew drug dealers. Drug dealers knew him. Any police movement meant the risk of murder, whistleblowing, headlines, scandal, and direct contamination of the ongoing acquisition.

At this time, doing “the right thing” is not following the manual.
It's about following the best strategy.

The decision in Copenhagen

I took the case directly to the board in Denmark.
Not to present more evidence—but to redefine the course.

I explained clearly:

• The recoverable money would come from those involved internally.
• The insurance would cover the rest.
• What was lost was lost.
• To call the police was to open the door to a global disaster.

And most of all:
It was necessary to clean up the entire company - not just the direct culprits, but everyone who, by function or omission, should have seen and not seen. Neglect also eats away at culture.

When I finished, there was silence.
Then the chairman of the board took a deep breath and said:
“Thank God. Finally someone telling us what we really need to do.”

The outcome

Management approved the strategy.
The company was sanitized.
Reconstructed governance.
Risks eliminated.
Purchase preserved.

And most importantly:
No scandal. No headline. Without destruction of value.

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