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Our attorneys assist clients around the globe in navigating the challenges presented by the constantly evolving climate of government regulation and enforcement of anti-bribery and anti-corruption laws.

Helping Clients Address Risks

The Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) should be expected to continue with enforcement of the Foreign Corrupt Practices Act (FCPA), particularly with regard to foreign entities and individuals. The DOJ’s anti-corruption enforcement arsenal also now includes the recently enacted Foreign Extortion Prevention Act (FEPA). Individuals and companies conducting international transactions subject to the FCPA and FEPA face significant risk due to enactment of similar anti-corruption laws by foreign countries, strengthened export control laws and heightened scrutiny of cross-border transactions. FEPA, which criminalizes the “demand” side of bribery by expressly prohibiting the solicitation and acceptance of bribes by foreign government officials, expands the government’s ability to prosecute foreign corruption, acting as a complement to the decades-old FCPA. 

  • Represented a manufacturing company in an FCPA matter that resulted in the company entering into a non-prosecution agreement and receiving a significant reduction in the fine. Due to the company’s remedial efforts, the DOJ did not require a monitor, instead trusting us to implement the terms of the agreement. We presented annual reports on the company’s progress in monitoring and enhancing its compliance policies and procedures to the leadership of the DOJ’s Fraud Section to efficiently close out the terms of the agreement.
  • Represented a chemical company in an FCPA matter with the DOJ and the SEC that resulted in a non-prosecution agreement, no compliance monitor and a substantial reduction in the amount of the fine.
  • In a case that made international headlines, represented a sports marketing company based in Buenos Aires in defending against a federal indictment for wire fraud and money laundering, stemming from bribes in contracts for sports marketing in the FIFA investigation. After a two-month jury trial, the U.S. district judge issued a 55-page order granting our motion to fully vacate and reverse the conviction.
  • Represented a high-level executive and owner of a major shipping company in an FCPA investigation conducted by Brazil and the DOJ where charges were brought against others but the investigation was closed without further action related to our clients.
  • Represented a market-leading energy company when the due diligence surrounding an anticipated acquisition brought concerns of possible FCPA violations committed by a former foreign agent of a successor entity. We verified the integrity of the client’s operations and made recommendations to enhance the company’s controls as the transaction moved forward.
  • Served as pool counsel and individually represented several U.S. and international high-level executives in numerous matters, including the former CFO of a NYSE company, a law firm partner, the general counsel of an international company’s Asia Region, the former CEO of a foreign subsidiary of technology company and a third-party agent, before the DOJ and the SEC in FCPA investigations, resulting in the declination of charges against the individuals.
  • Represented a third-party agent in a high-profile DOJ FCPA investigation and secured a rare non-prosecution agreement for the client.
  • Conducted an internal investigation for a public company and represented the company in a voluntary FCPA self-disclosure to the DOJ Fraud Section and the SEC that resulted in a rare non-public declination of prosecution from the DOJ and closure of investigation without action from the SEC.
  • Represented a multinational company in an acquisition of foreign subsidiaries with pre-existing FCPA violations. In addition to providing advice concerning the legal ramifications of the transaction, the team investigated and analyzed the economic impact of improperly obtained contracts on the current and future financial performance of the acquired subsidiaries.
  • Represented the German subsidiary of a U.S. parent company in an FCPA investigation resulting in the declination of charges by DOJ.
  • Advised a Swiss-based manufacturer on FCPA risks associated with a contemplated initial public offering in the U.S., in light of the company’s past history of making improper payments to government agents.
  • Advised a private aviation services provider on the FCPA risks attendant to maintaining a subsidiary and doing business in India.
  • Advised a major U.S. energy company regarding the FCPA risks and requirements associated with doing business with the Nigerian National Petroleum Corporation.
  • Represented a major international pharmaceutical company by conducting internal investigations into allegations of FCPA violations in Asia, South America and Europe.
  • Conducted an internal investigation on behalf of a Greek shipping company as part of the “Lava Jato” anti-corruption investigation in Brazil, also known as “Operation Car Wash.”
  • Advised a U.S.-based hedge fund in connection with FCPA issues in Central Asia.
  • Advised a U.S. bus manufacturer on avoiding FCPA problems in business transactions with Angola and other oil-producing nations.
  • Represented a former CFO of a NYSE company in DOJ and SEC investigations concerning the FCPA.
  • Represented many companies in FCPA matters that resulted in a non-prosecution agreement, no compliance monitor and a substantial reduction in the amount of the fine. The representations included assistance in compliance with the terms of the non-prosecution agreement.
  • Represented several high-level executives before the DOJ and the SEC in FCPA investigations, resulting in the declination of charges against the individuals.
  • Designed and implemented comprehensive compliance programs to prevent and detect potential anti-corruption risks for numerous companies, including developing compliance policies and training programs, and drafting and reviewing contracts with agents, distributors and other third parties.

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