Anti-Corruption, Export Controls & Sanctions
We regularly work with companies to conduct internal investigations and to establish policies, procedures, training programs, and other due diligence practices to ensure compliance with the Foreign Corrupt Practices Act (FCPA) and other relevant U.S. and foreign anti-corruption laws.
We also represent companies and individuals during all stages of enforcement proceedings, from advising companies on whether to self-disclose a suspected violation, to responding to and resolving government inquiries. Our scope is global – we have conducted investigations all over the world, including many places considered to pose the greatest risk to U.S. companies doing business abroad.
Representative Cases
- Served as legal counsel to FCPA Corporate Monitor of a multinational corporation in connection with deferred prosecution agreements with the DOJ and SEC. Monitor’s mandate was to review and independently verify the suitability of the company’s compliance program, recommend best practices for an anti-corruption program, ensure accurate accounting of books and records, and verify existence of sufficient internal controls to adequately support compliance efforts
- Preparation and execution of voluntary disclosures of suspected FCPA violations to the DOJ and the SEC
- Successfully represented international company before the SEC and DOJ from allegations of bribing foreign officials. Persuaded government to close investigation
- Representation of a number of multinational corporations in anti-corruption investigations in Africa, Asia, Central and South America, Eastern Hemisphere (including Russia and Kazakhstan), Europe and the Middle East
- Representation of publicly-traded company in internal and government anti-corruption investigation that involved the FCPA, UK Bribery Act of 2010 and related issues
- Representation of target company in investigating and disclosing anti-corruption and export control issues to the acquiring company and to the government
- Representation of an officer and director in FCPA investigations
- Representation of company in investigating and disclosing anti-corruption issues in a potential merger
- Representation of a public company in connection with an SEC investigation into bribery allegations in Russia. The SEC terminated the matter, taking no action against the company
- Conducted numerous international risk assessments for companies and assisted in any remediation, including adjusting the compliance program if warranted and conducting training
- Development of policies, procedures, training materials, handbooks and other materials to ensure compliance with the FCPA
- Advised company concerning whether certain gifts to state-run bank officials in China constitute violations of the FCPA
- Advised company concerning the FCPA compliance of its business activities in Poland
- Representation of a defense contractor in connection with allegations of export control violations
- investigation into allegations of export violations involving the sale of prohibited technology to the Chinese military
- Representation of Spanish national extradited to the United States in connection with allegations of violations of Arms Export Control Act and wire fraud
- Representation of licensed professional against allegations of unlawful export of goods to an embargoed country