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    Anticorruption – FCPA & UKBA

    Our global Anticorruption and Foreign Corrupt Practices Act (FCPA) team works with clients to create and implement cross-border solutions that address issues around the anticorruption laws embodied in the FCPA, UK Bribery Act (UKBA), Organization for Economic Cooperation and Development (OECD) Convention, Inter-American Convention Against Corruption, Council of Europe Criminal and Civil Law Conventions, and the UN Convention Against Corruption.

    We help our clients comply with global anticorruption laws and regulations to mitigate their risks and minimize their exposure to government investigations, prosecutions and derivative litigation. For example, we advise our clients on how to implement and maintain robust anticorruption compliance programs, including policies and procedures and internal controls. We also conduct internal investigations around the world and represent clients in proceedings involving US and foreign enforcement agencies. In addition, we counsel clients on their rights as victims of FCPA violations, and their potential entitlement to recover funds, including under the Crime Victims’ Rights Act (CVRA) and the Mandatory Victim Restitution Act (MVRA), as well as advising on broader financial crime issues, including obligations under the Dodd-Frank Act, Sarbanes-Oxley Act, and economic sanctions.

    Our Anticorruption and FCPA team members are located throughout our global footprint. In the US, our team includes former federal prosecutors from various offices within the US Department of Justice (DOJ), along with former US attorneys and assistant US attorneys, all of whom have extensive experience with anticorruption and FCPA investigations and proceedings before the DOJ and the Securities & Exchange Commission (SEC). Our US colleagues also regularly advise clients on anticorruption and FCPA issues arising out of Latin America. 

    In the UK, we have advised on numerous bribery and corruption cases over the last 10 years. Our British team has significant expertise in conducting internal investigations, defending clients facing government investigations and prosecutions, and advising on self-reporting. The team includes a former Serious Fraud Office (SFO) and Financial Services Authority (FSA) (as it then was) prosecutor. We have assisted multinational corporates with the design, implementation and testing of their anti-bribery and anti-money laundering policies and procedures. Our colleagues in the EU are well-versed with the various anticorruption laws of the EU member states. 

    In the Asia Pacific region, our team has extensive knowledge of the anticorruption laws and regulations of Australia, Singapore, the People’s Republic of China, Hong Kong, and Japan.

    Our Dubai-based Middle East team regularly conducts internal investigations into alleged misconduct and international investigations into alleged noncompliance by foreign agents and business partners, as well as compliance assessments to identify deficiencies or conduct issues that could give rise to enforcement liability, and remediation projects to resolve gaps, operationalize policies, and mitigate risks to business operations. In addition, our Middle East team has also counseled clients in major FCPA and UKBA representations in countless countries across the Gulf Cooperation Council (GCC), the Levant, and Africa and Asia. 

    Depending on clients’ global needs, we can call upon our lawyers who are resident in specific countries, fluent in the native languages and familiar with the local laws and jurisdictions.

    Explore

    We provide the following full range of anticorruption services:

    • Risk assessment
    • Compliance program gap analyses
    • Preparing and implementing anticorruption compliance policies and training
    • Due diligence on third parties, joint venture (JV) partners, and mergers and acquisitions (M&A) targets
    • Audits
    • Internal investigations
    • Contract representations, warranties language, indemnification and audit rights
    • Defense of enforcement proceedings brought by the DOJ, SEC, SFO, and other foreign enforcement agencies
    • Voluntary disclosures
    • DOJ opinion requests
    • Assessment and litigation of claims for restitution under applicable statutes

    Representative Experience

    • Multinational corporation in the oil and gas industry – Serving on the FCPA compliance monitor team for this company in connection with a deferred prosecution agreement (DPA) and settlement agreement with the DOJ and SEC, and conducting independent compliance reviews of the company’s operations in Africa and Asia.
    • Latin American state-owned energy companies – Represented multiple state-owned energy companies in seeking to be declared victims of FCPA violations and to obtain restitution under US law.
    • Europe-based multinational infrastructure company – Conducted a global internal investigation and defended the company in a multiyear, global FCPA investigation resulting in one of the most significant FCPA resolutions to date.
    • NYSE-listed company – Conducting an investigation on behalf of our client in response to whistleblower allegations at its Russia-based subsidiary concerning the FCPA, UKBA and local tax laws.
    • China-based US public company – Representing the audit committee and performing an independent investigation concerning the FCPA and SEC financial disclosures.
    • NYSE-listed company – Investigating of potential FCPA violations at locations in Mexico.
    • Fortune 500 companies – Representation in conducting FCPA due diligence in global M&A and joint ventures.
    • Publicly traded US-based wholesale electricity supplier – Representing this client, with substantial renewable energy assets, in an anticorruption investigation in Spain.
    • Fortune 500 companies – Representing in FCPA internal investigations in Brazil, China, the Dominican Republic, Greece, Honduras, Italy, Poland, Russia, Spain and Venezuela, including revising and drafting corporate FCPA compliance and integrity codes.
    • Global equipment manufacturer and distributor – Advising a global manufacturer and distributor of industrial equipment with FCPA/anticorruption matters. We created an internal audit program focused on controls for FCPA/anticorruption, and worked with its internal audit department in auditing the controls of the company in Latin America and Europe. We also conducted FCPA/anticorruption training in numerous countries, including Brazil, Poland, Russia and Germany.
    • Various Latin America clients – Assisting in the review and revision of anticorruption policies and procedures and advising Brazilian entities on FCPA/anticorruption compliance, including company practices, internal compliance programs, human resources concerns and remedial measures for improving compliance.
    • Fortune 500 companies – Training employees, as well as compliance-, auditing- and legal-staff on FCPA, UKBA and anticorruption laws and compliance.
    • US public company – Conducting anticorruption training in the native language in multiple countries.
    • Global telecommunications company – Counseling audit committee in connection with a worldwide white collar crime investigation into possible corrupt payments to government officials, which led to an early settlement of approximately US$1.6 billion.
    • Global medical devices and therapy company – Advising with respect to six separate FCPA and UKBA inquiries in India, including conducting internal and key distributor investigations into alleged improper payments to government health care professionals, advising on the development of the company's internal business conduct standards and third-party compliance procedures, and reporting to the DOJ and SEC as to the same (resulting in a formal declination).
    • World’s largest retail corporation – Counseling on several FCPA and UKBA inquiries in India, including conducting internal investigations into alleged improper payments and alleged issuance of improper benefits to government officials, and reporting to the DOJ and SEC as to the same.
    • Member of ruling family Emirate of Dubai – Advising following an internal investigation touching upon the motorsport industry and Brazil.
    • International pharmaceutical company – Counseling regarding an FCPA and UKBA inquiry in Iraq, including conducting internal and key distributor investigations into alleged improper payments to government health care professionals.
    • International metals company – Advising on the voluntary disclosure to the DOJ and SEC of alleged improper payments made to government officials in Bahrain.
    • Multinational technology and consulting corporation – Advising on three separate and distinct FCPA and UKBA inquiries in Algeria and Tunisia, including conducting internal investigations into alleged improper payments to government officials.
    • Global oilfield product-manufacturing entity – Advising with respect to FCPA-related due diligence on a host of its foreign agents and business partners operating across the Middle East and North Africa (MENA) and Levant Regions.
    • Worldwide industrial services and engineered solutions company – Advising with respect to FCPA and UKBA issues in the Kingdom of Saudi Arabia, including advising on the development of the company's existing internal compliance controls and the creation and implementation of supplemental anticorruption compliance program components.

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    • Multinational corporation in the oil and gas industry – Serving on the FCPA compliance monitor team for this company in connection with a deferred prosecution agreement (DPA) and settlement agreement with the DOJ and SEC, and conducting independent compliance reviews of the company’s operations in Africa and Asia.
    • Latin American state-owned energy companies – Represented multiple state-owned energy companies in seeking to be declared victims of FCPA violations and to obtain restitution under US law.
    • Europe-based multinational infrastructure company – Conducted a global internal investigation and defended the company in a multiyear, global FCPA investigation resulting in one of the most significant FCPA resolutions to date.
    • NYSE-listed company – Conducting an investigation on behalf of our client in response to whistleblower allegations at its Russia-based subsidiary concerning the FCPA, UKBA and local tax laws.
    • China-based US public company – Representing the audit committee and performing an independent investigation concerning the FCPA and SEC financial disclosures.
    • NYSE-listed company – Investigating of potential FCPA violations at locations in Mexico.
    • Fortune 500 companies – Representation in conducting FCPA due diligence in global M&A and joint ventures.
    • Publicly traded US-based wholesale electricity supplier – Representing this client, with substantial renewable energy assets, in an anticorruption investigation in Spain.
    • Fortune 500 companies – Representing in FCPA internal investigations in Brazil, China, the Dominican Republic, Greece, Honduras, Italy, Poland, Russia, Spain and Venezuela, including revising and drafting corporate FCPA compliance and integrity codes.
    • Global equipment manufacturer and distributor – Advising a global manufacturer and distributor of industrial equipment with FCPA/anticorruption matters. We created an internal audit program focused on controls for FCPA/anticorruption, and worked with its internal audit department in auditing the controls of the company in Latin America and Europe. We also conducted FCPA/anticorruption training in numerous countries, including Brazil, Poland,
      Russia and Germany.
    • Various Latin America clients – Assisting in the review and revision of anticorruption policies and procedures and advising Brazilian entities on FCPA/anticorruption compliance, including company practices, internal compliance programs, human resources concerns and remedial measures for improving compliance.
    • Fortune 500 companies – Training employees, as well as compliance-, auditing- and legal-staff on FCPA, UKBA and anticorruption laws and compliance.
    • US public company – Conducting anticorruption training in the native language in multiple countries.
    • Global telecommunications company – Counseling audit committee in connection with a worldwide white collar crime investigation into possible corrupt payments to government officials, which led to an early settlement of approximately US$1.6 billion.
    • Global medical devices and therapy company – Advising with respect to six separate FCPA and UKBA inquiries in India, including conducting internal and key distributor investigations into alleged improper payments to government health care professionals, advising on the development of the company's internal business conduct standards and third-party compliance procedures, and reporting to the DOJ and SEC as to the same (resulting in a formal declination).
    • World’s largest retail corporation – Counseling on several FCPA and UKBA inquiries in India, including conducting internal investigations into alleged improper payments and alleged issuance of improper benefits to government officials, and reporting to the DOJ and SEC as to the same.
    • Member of ruling family Emirate of Dubai – Advising following an internal investigation touching upon the motorsport industry and Brazil.
    • International pharmaceutical company – Counseling regarding an FCPA and UKBA inquiry in Iraq, including conducting internal and key distributor investigations into alleged improper payments to government health care professionals.
    • International metals company – Advising on the voluntary disclosure to the DOJ and SEC of alleged improper payments made to government officials in Bahrain.
    • Multinational technology and consulting corporation – Advising on three separate and distinct FCPA and UKBA inquiries in Algeria and Tunisia, including conducting internal investigations into alleged improper payments to government officials.
    • Global oilfield product-manufacturing entity – Advising with respect to FCPA-related due diligence on a host of its foreign agents and business partners operating across the Middle East and North Africa (MENA) and Levant Regions. 
    • Worldwide industrial services and engineered solutions company – Advising with respect to FCPA and UKBA issues in the Kingdom of Saudi Arabia, including advising on the development of the company's existing internal compliance controls and the creation and implementation of supplemental anticorruption compliance program components.