Unfortunately, and unless I am mistaken, the FCPA net would not catch these criminals just because of the dollar being used.   The parties need some kind of US connection, which can be very wide, but I don't see it here.   If they had dual listed securities or branches in the US, maybe.

Standard Chartered has a problem though, if it was aware of various legs.  But if they were one transaction, maybe not.

KPMG has several problems.   Besides the theft of state aid that might be disguised as a purchase of dairy equipment, the tax angle on deducting the wedding expense is beyond believable.    It is a pity, not all their people are pond scum so they really need to clean house immediately or face their own Anderson Enron moment.    You will see group of clean partners launch a mutiny.