FCPA & Anti-Corruption

Our FCPA & Anti-Corruption team has extensive experience representing clients in all facets of compliance, investigations and enforcement.

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  Compliance

  We have extensive experience developing and enhancing compliance programs, conducting risk assessments and developing effective financial controls to detect and prevent corruption. In addition to creating, enhancing and implementing anti-corruption compliance programs, we have extraordinary experience monitoring and assessing compliance. Our team has been engaged by companies throughout the world to develop compliance programs addressing FCPA-related risk and has been engaged by those companies and many others to investigate compliance related issues. A member of our team has been selected twice by the DOJ and SEC to serve as an FCPA compliance monitor. Moreover, another member of our team served for more than five years as Co-General Counsel and Chief Compliance Officer of one of the world’s largest multinational oilfield service companies, while the company was in the midst of an FCPA and Sanctioned Country investigation. He aided the company in establishing what is widely recognized as a best-in-class compliance program.

  Enforcement

  Over the past 10 years, the U.S. government and governments around the world have committed tremendous resources to investigating and prosecuting alleged corruption. Our lawyers have extensive experience with the DOJ and SEC, having represented many companies and individuals in front of those agencies for years. Our success in these matters is perhaps exemplified by our ability to obtain declinations for companies in different industries despite long, contentious government investigations. Our attorneys also have valuable experience with the U.K. Serious Fraud Office and other regulators around the world.

  In addition to government prosecutions, the world’s major multilateral development banks (MDBs), such as the World Bank, have increased their focus on corruption in recent years. Our attorneys are handling multiple matters in front of the MDBs, which present their own unique procedures and challenges. We guide our clients through these investigations and advocate on behalf of our clients throughout all phases of the sanctions process.

  A Confident, Measured Approach to Internal Investigations

  Each year, we handle many internal investigations concerning possible corruption. We pride ourselves on bringing a measured approach to these engagements by handling them in a cost-conscious and efficient manner. We utilize our global platform to bring requisite cultural and language skills to the investigations we perform all over the globe. We recognize that most investigations are not "bet the company" matters, and we treat them accordingly. When the rare enterprise-risk matter does arise, we are able to bring the appropriate resources to bear.

• Engagements

  Government Investigations

  • Represented a multinational medical device company through an industry-wide DOJ and SEC investigation, resulting in a declination of prosecution for our client.
  • Representing an international medical device company in front of the DOJ and SEC following its entry into a deferred prosecution agreement.
  • Representing a Russian government official in a high-profile FCPA criminal investigation involving charges of extortion related to lobbying contracts concerning the sale of downgraded Russian nuclear fuel to utilities in the United States for use in civil nuclear reactors.
  • Representing an oilfield services company in a DOJ investigation pertaining to alleged corruption in South America.
  • Representing the former chairman of an international investment bank overseeing greater China in connection with a DOJ and SEC investigation of hiring practices in financial services companies throughout Asia (often referred to as the princeling investigation).
  • Representing three current and former employees of a multinational pharmaceutical company in an FCPA investigation by the DOJ and SEC.
  • Representing a multinational pharmaceutical company in connection with a DOJ and SEC FCPA investigation, including compliance with a deferred prosecution agreement with DOJ.

  Internal Investigations

  • Serving as investigative counsel to a Fortune 50 company, conducting FCPA internal investigations in the United States, Europe, South America, Central America, Africa, Japan, China, India, Mozambique, Bangladesh and other regions.
  • Leading an internal investigation on behalf of an Asian chemical company having to do with potential bribes to government officials in a third Asian country. Our Tokyo office is assisting in the investigation and counseling on the U.S. FCPA implications of the conduct at issue.
  • Conducting internal investigations on behalf of a multinational pharmaceutical company in connection with suspected FCPA violations by subsidiaries and distributors in Europe, Asia and South America.

  World Bank Enforcement

  • Representing several companies across multiple industries operating in Europe, Asia and Africa in connection with investigations by the World Bank Group Department of Integrity Vice Presidency (INT) relating to allegations of fraud, corruption, collusion and obstruction in connection with World Bank-financed projects.

  Compliance and Monitorships

  • Selected twice by the DOJ and SEC to serve as an independent FCPA Monitor.
  • Serving as compliance counsel for a life sciences multinational and enhancing the company’s anti-corruption compliance program following a merger.
  • Serving as compliance counsel for several oil and gas companies operating in South America, Africa, Europe and the Middle East.
  • Serving as compliance counsel for a Silicon Valley semi-conductor manufacturer with operations in the United States and Asia.
  • Serving as compliance counsel for a cruise line.
  • Developing anti-corruption compliance policy and procedures for an oil and gas refining company with global operations.
  • Conducting FCPA due diligence on behalf of Johnson Controls Inc. in connection with its $1.5 billion joint venture, which involved intensive investigatory work in more than 10 countries in Asia.
  • Performing pre-acquisition anti-corruption diligence for extractive energy company on a South American target.
  • Advising the board of directors of a Colombian mining company. regarding anti-corruption risk in a deal.
  • Performing anti-corruption diligence and audits on third-party distributors throughout Brazil for a multinational medical device company.
  • Conducting extensive anti-corruption due diligence on an oil and gas company’s agents and joint venture partners in Senegal, Ghana, Morocco, Guinea and Kurdistan.
  • Performing upwards of 40 due diligence exercises in the oil and gas sector across the globe.