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FCPA & Global Anti-Corruption

Experience Highlights

  • Representing the Audit Committee of a public technology company in connection with allegations from multiple whistleblowers of Foreign Corrupt Practices Act (FCPA) violations in several countries, including in connection with related SEC and DOJ investigations

  • Conducted an internal investigation for a U.S.-based oilfield services company regarding potential compliance violations of the FCPA and UKBA relating to improper payments regarding travel, hospitality, and entertainment for employees of a Chinese state-owned client. Had extensive discussions with the Board and Audit Committee, including issues related to possible disclosures to authorities

  • Represented two U.S. companies in a coordinated DOJ and SEC FCPA investigation of the energy industry in West Africa and succeeded in having cases closed without the government taking any action against the clients

  • Conducted internal investigation of FCPA compliance for a public multinational technology company regarding sales practices in the Middle East

  • Representing ten senior officers and employees of a commercial real estate development company in large scale FCPA investigation by the DOJ and SEC regarding permitting and licensing in a Latin American country

  • Conducted multiple internal investigations for a U.S.-based natural gas products and services company regarding potential FCPA and embezzlement violations, including in connection with the company’s operations in Kazakhstan and Libya

  • Representing an SEC-registered investment advisor and private equity firm to develop and implement a compliance program to evaluate and manage risks across its worldwide portfolio, conduct pre-investment due diligence, and train firm’s directors

  • Conducted an internal investigation for an international oil company regarding potential FCPA compliance violations in connection with company’s operations with a national oil company in a Middle Eastern country

  • Advising in connection with a Serious Fraud Office Investigation arising out of the UN’s Oil For Food Programme

  • Assisted global manufacturer and distributor of chemicals to conduct an internal investigation related to potential allegations of corruption at a joint venture in India; received declination letters from both the SEC and DOJ

  • Conducted internal investigations into potential breaches of the UK Bribery Act for an African telecommunications company