Rich Gibbon is a partner in our Government Investigations & White Collar Practice and focuses on white collar criminal defense, regulatory enforcement and internal investigations. He has been based in the Middle East for 12 years and has extensive experience managing crises and counselling boards of directors and senior management across the Middle East and Africa, Levant, Europe, and South Asia through multi-agency, multi-jurisdictional financial crime investigations and enforcement actions. This includes multinational corporates in connection with anticorruption 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 indorsed several times as a “White Collar Crime Adviser of the Year.” The Legal 500 labels Rich "extremely diligent" and notes that he "rolls his sleeves up and gets into the detail when addressing client issues." Chambers Global states that Rich “understands complex financial transactions as well as any forensic accountant.”
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 guiding clients when responding to criminal and civil government inquiries. Rich is presently assisting numerous different financial institutions across the Middle East and Africa, Levant, Europe and South Asia with investigations and transactional audits of potential violations of US sanctions and money laundering laws and with related proceedings before OFAC, the US Department of Justice (DOJ), the New York State Department of Financial Services (NYDFS), and several other US and home-country enforcement agencies and regulators. Rich also advises financial institutions on collateral issues arising from sanctions and money laundering matters, including facilitating relationships with US correspondent banks, and he represents financial institutions and other corporates in OFAC Specially Designated National (SDN) delisting engagements.
Rich has also counselled 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, he has addressed the implications of relevant laws in the context of M&A due diligence, he has assessed, improved, and reformed business conduct standards and compliance controls, and he has provided training sessions.
Rich is well-versed in helping clients to comply with global anticorruption and money laundering laws, economic sanctions regulations, and international trade and export controls, in order to mitigate risks and exposure to government investigations, prosecutions, and derivative litigation. 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, and assuage risks to business operations.
Rich also lectures and acts as thesis advisor at the Paris-Sorbonne University in Abu Dhabi on the International Business Law Master’s Degree, and regularly writes and speaks on global financial crime compliance. Rich is a graduate of Cambridge University and a Certified Fraud Examiner (CFE).
Government Investigations & White Collar
International Dispute Resolution