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Internal Investigations

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 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

  • 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

  • (D.C. Cir.); (D.D.C.) — Represented a government contractor in qui tam action in which V&E successfully obtained two writs of mandamus vindicating the contractor’s claim of attorney-client privilege over materials created during an internal investigation led by company lawyers; subsequently won summary judgment on all counts

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

  • Represented an energy company in an internal investigation into allegations of impropriety in the company’s procurement group, including conflicts of interest with major vendors and an allegation of misappropriation of company assets

  • Conducted an internal investigation, in cooperation with the SEC, for a public company into allegations of potential violations of the Foreign Corrupt Practices Act in China and Hong Kong, and allegations of undisclosed director conflicts of interest

  • Represented the board of directors of a large, privately held real estate development and construction company in an internal investigation into whether one of its branch offices was engaged in an office-wide scheme to defraud the company and its customers on a number of private and government-funded construction projects

  • Conducted an internal investigation for a private construction company into allegations of employee fraud and overbilling government agencies

  • Represented Audit Committee of a public telecommunications company in an internal investigation of pay-for-play leading to the award of a contract from a local government

  • Conducted an expedited internal investigation for a private international company into potential violations of the Foreign Corrupt Practices Act and federal anti-money laundering laws associated with suspicious payments in Africa