Anti-Corruption and Foreign Corrupt Practices Act (FCPA) Investigations and Compliance

Investigations

Served as legal counsel to FCPA Corporate Monitor of a multinational corporation in connection with deferred prosecution agreements with the DOJ and SEC. Monitor’s mandate was to review and independently verify the suitability of the company’s compliance program, recommend best practices for an anti-corruption program, ensure accurate accounting of books and records, and verify existence of sufficient internal controls to adequately support compliance efforts

Representation of a number of multinational corporations in anti-corruption investigations in Africa, Asia, Central and South America, Eastern Hemisphere (including Russia and Kazakhstan), Europe and the Middle East

Representation of publicly-traded company in internal and government anti-corruption investigation that involved the FCPA, UK Bribery Act of 2010 and related issues

Preparation and execution of voluntary disclosures of suspected FCPA violations to the DOJ and the SEC

Successfully represented international company before the SEC and DOJ from allegations of bribing foreign officials.  Persuaded government to close investigation

Representation of target company in investigating and disclosing anti-corruption and export control issues to the acquiring company and to the government

Representation of company in investigating and disclosing anti-corruption issues in a potential merger

Representation of an officer and director in FCPA investigations

Representation of a public company in connection with an SEC investigation into bribery allegations in Russia.  The SEC terminated the matter, taking no action against the company

Compliance

Conducted numerous international risk assessments for companies and assisted in any remediation, including adjusting the compliance program if warranted and conducting training

Development of policies, procedures, training materials, handbooks and other materials to ensure compliance with the FCPA

Advised company concerning whether certain gifts to state-run bank officials in China constitute violations of the FCPA

Advised company concerning the FCPA compliance of its business activities in Poland