A Polish construction company faced a situation where a consortium of Turkish firms submitted artificially low bids in a tender for the construction of an infrastructure project. This created the risk of a non-competitive contractor selection.

The client developed well-founded concerns regarding the compliance of the tender participants and the sources of their financing, including possible links to sanctioned capital. To substantiate these concerns, it was necessary to collect admissible evidence that could serve as grounds for disqualifying the competitors and strengthening the client’s position in challenging the tender results.

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The task was to determine whether the tender participants complied with legal and compliance standards, as well as to identify potential hidden links to sanctioned individuals or sources of sanctioned capital. The opportunity lay in applying Data Research tools to analyze ownership structures, financial flows, international connections, the execution of large projects for sanctioned parties, or the generation of other income from associations with sanctioned entities. This made it possible to prepare an evidentiary basis that strengthened the client’s position in challenging the tender outcome.

1. Verification of participants’ compliance with tender requirements.
Reducing the risk of awarding the contract to a non-compliant bidder.
Task: Identify violations of tender conditions by competing bidders, specifically in terms of ownership structure, transparency of funding sources, and corporate compliance, and document these violations with admissible evidence

2. Identification of sanctioned capital involvement through concealed links.
Legal grounds for disqualification of participants.
Task: Uncover the involvement of entities controlled by sanctioned persons in the consortium’s financing by identifying indirect relationships, transactions, and joint economic activities

3. Preparation of an admissible evidentiary base for formal proceedings.
Strengthening the client’s position before the tender committee and regulatory bodies.
Task: Compile a complete package of verified and admissible evidence to support official complaints, initiate an internal review, and assist the legal team in contesting the tender outcome

4. Jurisdictional analysis to support escalation and cross-border pressure.
Ensuring procedural control in a multi-jurisdictional environment.
Task: Identify jurisdictions where violations can be recorded, activate regulatory instruments, or leverage the compiled dossier in the client’s interest, including in antitrust and compliance procedures

5. Securing procedural and informational advantage in the tender.
Strengthening the client’s position at the final selection stage.
Task: Provide argumentation tools that enable the client to influence the tender process, present substantiated objections, and propose alternative contractor selection scenarios

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The Anahata Solutions team conducted a thorough investigation of the ownership structure, financial flows, and business connections of the Turkish consortium. Using Data Research tools, the team analysed corporate registries, financial statements, international contracts, audit reports, documentation from construction self-regulatory organizations in high-risk jurisdictions, reports from state regulators, antitrust investigation materials, and project documentation from completed infrastructure developments. This multifaceted investigation uncovered business ties between the consortium and Russian investors, including sanctioned individuals and affiliated entities, confirming that the consortium received revenues from sources connected to sanctions in violation of the tender requirements.

The materials we prepared did not replace the work of the client’s legal teams but significantly enhanced it. We compiled structured dossiers and evidentiary packages that enabled the lawyers to file formal compliance complaints, initiate an internal review by the tender committee, and defend the client’s competitive position.

The dossier developed by our team allowed the client’s advisors to promptly and convincingly trigger an internal investigation by the tender committee, which laid the groundwork for contesting the results of the infrastructure tender. The foundation for this action was the evidence that the consortium, which had submitted a non-market bid, had received income from projects linked to sanctioned capital.

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• Review of corporate registries, ownership structures, and offshore entities to identify beneficial owners and uncover hidden affiliations.

• Examination of financial statements, audit reports, and project documentation to track financial flows related to projects and companies operating in high-risk jurisdictions.

• Assessment of international contracts and foreign trade operations that confirmed revenues from projects involving sanctioned capital.

• Analysis of documentation from construction self-regulatory organizations in high-risk jurisdictions, along with reports from government regulators and antitrust investigation materials.

• Consolidation of all collected data into a single structured dossier and preparation of evidentiary packages used by the client’s legal team to substantiate compliance violations and contest the tender outcome.

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