Case Result: Non-Referral Decision (No Suspicion) for Alleged Acceptance of Benefits in Breach of Trust

1. Analysis of Fund Flows and Contractual Structure

We systematically organized account transaction records, contracts, and internal materials to explain structurally that no direct quid pro quo relationship between the movement of funds and specific official acts could be objectively established.

We also organized objective evidence demonstrating that no clear direct connection existed between the timing of the fund transfers and the timing of the relevant decision-making.

2. Organization of the Scope of Duties and Decision-Making Structure

We clearly organized the client's actual scope of duties and approval structure and systematically examined whether the client could be deemed to have had the authority to make decisions independently or provide benefits in the matter at issue.

This was a key defense point in assessing the relationship between the alleged benefit and the client's duties.

3. Refinement of the Statement Strategy

In cases involving the alleged acceptance of benefits in breach of trust, the structure and consistency of the initial statements are important.

We organized the client's statements so that they would not conflict with the fund flows or the business structure and adjusted expressions that could give rise to unnecessary misunderstandings, thereby focusing the response on whether the quid pro quo relationship could be proven.

Non-Referral