John A. Rademacher

John is a director in KPMG’s Investigations, Disputes, and Compliance network in the Chicago office. He focuses on forensic investigations, compliance transformation, and third-party risk management. He has led numerous investigations that have included regulatory investigations, asset misappropriation, financial reporting fraud, and bribery and corruption. He has led numerous compliance transformations that have included evaluations of compliance program frameworks, development of compliance strategies, and remediation through the design and implementation of compliance policies, procedures, processes, and controls to comply with regulatory obligations and mitigate compliance risks. He has experience serving clients of all sizes in various industries including life sciences and manufacturing. He has worked with clients domestically and internationally, including matters in Brazil, Vietnam, Japan, Poland, Serbia, Chile, Switzerland, Germany, Russia, Turkey, Hong Kong, China, and India.

Professional and industry experience

Risk and compliance services

• Engaged by in-house counsel to conduct a review of a large, private organization’s control framework relevant to ethics and integrity in response to regulatory enforcement action. This review included an assessment of the adequacy of ethics and integrity training and communications, the organization’s governance structure and culture of ethics and integrity, oversight of compliance with ethics and integrity requirements, and organizational structure responsible for key program elements. Identified gaps within the organization’s policies, procedures, and processes, and developed remediation plans to enhance its controls relevant to ethics and integrity requirements, and assisted the organization with reporting to its regulator.
• Conducted a global anti-bribery and corruption (“ABC”) risk assessment and gap analysis for a Fortune 500 financial services organization. Conducted inquiries of senior management regarding the ABC program design, implementation, and governance; performed ABAC-focused testing of approximately 1,800 transactions; analyzed policies and procedures governing risk areas; and evaluated the current state of the control framework in order to identify potential gaps and opportunities for enhancement of the compliance program. This assessment included understanding the policies, procedures, and controls related to the company’s lobbying activities at the federal, state, and local levels; contributions to political groups and organizations (including candidates and political action committees); interactions with government officials, political organizations, and industry groups, and assisting outside counsel in identifying and analyzing transactions with a higher risk of campaign finance violations.
• Engaged by Outside Counsel to perform a compliance transformation project at an automotive company. Conducted over thirty interviews of executives, general counsel, and compliance team members; developed recommendations for enhancements to the Compliance office, including the oversight, structure, and responsibilities, and created roadmaps to implement the identified recommendations. Assisted the company in optimizing resources in the Compliance Office.
• Assisted a US-based private equity firm with the acquisition of an international pharmaceutical company by conducting an assessment of the company’s compliance program, with a focus on compliance with the Foreign Corrupt Practices Act (“FCPA”). Designed and implemented controls to enhance its compliance program. Developed a Code of Conduct and key compliance policies and procedures (e.g., anti-bribery and corruption, expense reimbursement, compliance reporting, and investigation protocols, and other policies), conducted Code of Conduct and ABC training, and conducted due diligence of key third-party distributors.
• Conducted global risk assessments of a medical device manufacturer's international sites focusing on the subsidiaries' Accounting and Finance, IT, and Compliance functions. Acted as a PMO overall site assessments and oversaw the execution of fieldwork by KPMG teams located in Belgium, Switzerland, Germany, and France. Provided oral and written reports to the Chief Auditor, Chief Compliance Officer, and Global IT Director describing risks identified during the site assessments and observations and recommendations for improvement.

Forensic investigations

• Leads the execution of global investigations for global automotive manufacturers and suppliers, including investigations into violations of Anti-Bribery and Corruption laws and regulations, conflicts of interest, financial reporting fraud, violations of distributor agreements, and violations of company code of conduct, among others. Investigations include oversight of cross-functional teams including Forensic Technology, Data Analytics, and Corporate Intelligence and have included matters in Vietnam, South Korea, Argentina, India, China, Japan, Australia, and the United States, among others.
• Conducted an internal investigation for a large, private organization related to alleged regulatory violations, which included several hundred custodians and over 60 million documents. Oversaw a cross-functional investigative team that consisted of investigators, forensic technology, data analytics professionals, and a managed review team and used technology-assisted review (“TAR”) to perform early case assessments and conduct text analytics to inform the investigative strategy and identify misconduct with potential regulatory implications. Worked with outside counsel in conducting interviews of over 200 subjects and advising senior leadership on discussions regulators pertaining to the facts and circumstances identified during the investigation.