FCPA and Anti-Corruption

  • Conducted an internal investigation for a Fortune 500 company regarding alleged improper payments by an agent of its subsidiary in a South American country.
  • Conducted an internal investigation for a mid size US defense contractor regarding potentially corrupt payments in connection with a Middle East country contract and advised and guided the company through remediation, disclosure and settlement discussions.
  • Conducted an internal investigation for European subsidiary of a Fortune 100 company into allegations of corruption in a East European contract and advised company on remediation and resolution of dispute with sales agent.
  • Conducted an internal investigation for a multinational defense industry company regarding entertainment of foreign officials and represented company in disclosures to State Department, DOJ and SEC.
  • Conducted post-acquisition due diligence for major oil industry company of acquired entity’s operations in multiple countries.
  • Conducted internal investigations for multinational corporation into potential corruption problems in multiple jurisdictions including Sub-Saharan Africa and Latin America and advised on remediation.
  • Represented a major natural resources extraction company in an internal investigation of alleged improper payments made in a Latin American country and a voluntary disclosure.
  • Conducted an internal investigation covering potential violations in a southeast Asian, a West African and two South American countries made by a European subsidiary of a Fortune 100 corporation and advised the company on remediation and disclosure. Conducted an internal investigation for international aerospace contractor and provided advice regarding its relationship with former representative in an Asian country.  
  • Conducted an internal investigation into potential corrupt payments to various administrative entities of a North African country by employees of a major natural resources industry construction contractor and advised on remediation and potential disclosure.
     
  • Performed complete compliance review for a multi-national tobacco company, including assessment of the design and implementation of a multinational tobacco company's compliance program against applicable benchmarks and suggested possible improvements and evaluation of effectiveness of the company's compliance program.
  • Performed comprehensive, multi-phased compliance review of a large, international corporation. Reviewed draft policies, evaluated due diligence protocols, observed training programs, tested accounting procedures, and analyzed tone at the top. Conducted critical evaluation of implementation of compliance program components. Assessed entire compliance program against the U.S. Sentencing Guidelines and other benchmarks and provided guidance to improve the program. Presented analytical review of compliance program to the Department of Justice for consideration in FCPA case settlement negotiations.  Conducted an intensive onsite compliance audit at an overseas location of a major multi-national client. This compliance review, which included myriad foreign language interviews, was performed in cooperation with a large financial consulting firm and covered financial/accounting analysis, assessment of legal risks and adequacy of policy implementation.
  • Represented an international investment institution to provide advice and guidance on the adequacy of the company’s due diligence of third parties in several African countries. In addition, upon close review of the client’s FCPA policy and procedures, we revised their policies and procedures to make them comprehensive, practical, and tailored to the particular risks facing the client.
  • Advised international mining company concerning foreign mining company acquisitions and devised and supervised the client’s due diligence efforts related to the proposed acquisitions.
  • Advised private equity company regarding overhaul of compliance programs for acquired companies and, thereafter, implemented improved compliance programs for acquired companies.

2016 Mid-Year Update"Please click here for our Anti-Corruption Enforcement 2020 Year in Review



OUR PRACTICE IS GLOBAL

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