Anti-Corruption

Representative Experience

  • Represented a global company in the first FCPA investigation by the Department of Justice and the Securities and Exchange Commission of a Brazilian multinational, involving transactions in Latin America, Asia, the Middle East and Africa.
  • Represented a Brazilian corporation and U.S. “issuer” in one of the largest FCPA settlements of bribery allegations arising from Brazil’s Lava Jato (Operation Car Wash) anticorruption probe.
  • Represented an international construction company in an FCPA investigation related to a project in the Middle East.
  • Developed and implemented anti-corruption measures for addressing conflicts of interest and bribery in Ukraine.
  • Represented an officer of a German company with securities trading on U.S. exchanges in connection with a government investigation into possible bribery by the company’s affiliate in Africa.
  • Successfully advised U.S. mining original equipment manufacturer on developing and securing China-originating supply chain for drilling products by enhancing company’s FCPA compliance program and policy.
  • Conducted internal investigation into allegations of FCPA violations and bid-rigging by a foreign subsidiary of a major US-based global corporation; implemented remedial measures and appropriately addressed inappropriate conduct by certain employees.
  • Successfully advised an officer of a subsidiary of a global Swiss-based, US-listed company in a joint Justice Department and SEC FCPA investigation into payments made by the subsidiary in connection with the award of a major government contract in Ecuador. No charges were brought against our client.
  • Conducted a global corruption risk analysis, created and revised policies and procedures, and assisted in the implementation of a global anti-corruption program for a Fortune 100 global corporation with operations in 67 countries.
  • Successfully performed an internal investigation and implemented remedial measures to address bribery and corruption policy violations in a global company’s operations in India and reported results to the Justice Department and SEC, resulting in no charges and no findings against our client.
  • Defended, successfully, an executive in a joint SEC/Justice Department FCPA investigation. No charges were filed against our client.
  • Counseled international franchise system on FCPA exposure created by international franchisees, and designed a risk-based compliance program reflecting client operations in more than 25 countries.
  • Successfully defended a public accounting firm in response to informal SEC inquiries alleging accounting improprieties in connection with FCPA bribery allegations. No formal order of investigation was issued.
  • Advised U.S.-based medical services provider on FCPA issues related to joint venture hospital in China.
  • Counseled RFID chip manufacturer on mitigating FCPA risk in connection with Korean government purchase of chips.
  • Advised large U.S. retailer on FCPA risks in multi-jurisdiction supply chain.
  • Provided FCPA support in connection with U.S.-based investment fund's operations in Gulf Cooperation Council jurisdictions.
  • Advised large tobacco merchant in connection with voluntary disclosure under FCPA and settlement with the U.S. Department of Justice.