Rich Gibbon is a partner in our Government Investigations & White Collar Practice focused on internal investigations and global financial crimes compliance and defense. He has been based in the Middle East for 13 years and has extensive experience managing crises and counseling boards of directors and senior management across the Middle East, the Commonwealth of Independent States (CIS), Africa, Europe, the Levant, and Central and South Asia, through multiagency, multijurisdictional financial crime investigations and enforcement actions. This includes multinational corporates in connection with anti-bribery and corruption regimes and a particular concentration on matters related to financial institutions involving economic sanctions, money laundering and bank fraud. Due to the sensitive and confidential nature of Rich’s work, much of it is not public. Even so, he has been recognized as a “Leading Lawyer” across Europe, the Middle East and Africa for Compliance and Investigations, recommended as a “Global Leader” for Business Crime Defence and Investigations, and endorsed several times as a “White Collar Crime Adviser of the Year”. The Legal 500 labels Rich “the best investigations, compliance, crisis management, and reputation management partner there is”. The directory notes that he is “extremely diligent,” “masterful at distilling critical details from volumes of complex and technical material,” and “outright relentless in his pursuit of the best possible results or resolutions for his clients.” Chambers Global states that Rich “understands complex financial transactions as well as any forensic accountant” and “works tenaciously to unearth and piece together the facts.”
Rich has a wealth of experience advising on the scope of economic sanctions administered by the US Treasury Department’s Office of Foreign Assets Control (OFAC) and other international, regional and state bodies, and guiding clients when responding to related criminal and civil government inquiries. Rich also advises on collateral issues arising from political exposure, sanctions and money laundering matters, including facilitating relationships with US correspondent banks and other financial institutions, and he represents clients in sanctions delisting engagements. In addition, Rich has counseled clients across the defense and security, industrial services, medical devices and therapies, natural resources, pharmaceutical, oil and gas, retail, sporting, and technology sectors, in major US Foreign Corrupt Practices Act (FCPA) and UK Bribery Act (UKBA) representations in countless countries across the globe. He has conducted internal investigations into alleged misconduct and international investigations into alleged noncompliance by foreign agents and business partners, and he has addressed the implications of relevant laws in the context of M&A due diligence.
Rich is well-versed in helping clients mitigate risks and exposure to government investigations, prosecutions, and derivative litigation through robust compliance. He conducts high-level compliance assessments, or gap analyses, based on industry standards and international best practices, to identify deficiencies or conduct issues that could give rise to enforcement liability. He then collaborates with senior-level executives to develop comprehensive and customized solutions to resolve gaps, modify processes, augment compliance functions and internal controls, reform business conduct standards and assuage risks to business operations. He also provides internal training sessions to help operationalize compliance.
Of note, Rich recently served for six months as Interim Head of Group Ethics & Compliance for Etisalat by e&, an Emirati-based multinational telecommunications services provider currently operating in 16 countries across the Middle East, Asia and Africa. Rich also lectures and acts as thesis advisor at the Paris-Sorbonne University in Abu Dhabi on the International Business Law Masters Degree, and regularly writes and speaks on global financial crimes compliance. He is a graduate of Cambridge University and INSEAD, a Certified Fraud Examiner (CFE), and the firm’s Money Laundering Reporting Officer (MLRO).
Government Investigations & White Collar
International Dispute Resolution