Our lawyers have extensive experience assisting clients in matters arising under the Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act. Most members of our team previously served as federal prosecutors or securities enforcement trial attorneys, and attained senior management positions within the Office of the United States Attorneys, the DOJ or the SEC. We draw on that government experience to help our clients develop practical and efficient compliance programs, effectively manage investigations of suspected violations of anti-corruption laws, and successfully defend against charges of alleged violations of those laws.

FCPA Compliance

We assist clients in developing and implementing FCPA/anti-corruption compliance programs; provide advice regarding specific transactions and activities, enabling clients to minimize exposure under the anti-corruption statutes; and assist with due diligence for potential acquisitions and business transactions, enabling clients to avoid acquiring an FCPA or U.K. Bribery Act liability.

FCPA Investigations

We conduct internal investigations of potential violations and provide necessary and detail-appropriate reports to senior management, boards and/or audit committees. Our lawyers assist clients in formulating and implementing remedial and disciplinary measures when internal investigations confirm that law violations have occurred, and provide advice on whether the violations should be reported to the appropriate authorities.

FCPA Defense

We represent clients in responding to government investigations of alleged violations. In the event criminal charges or civil enforcement actions are filed and cannot be resolved, we defend our clients at trial. For example, one of our partners successfully represented a client in a four-month long trial, U.S. v. Goncalves (D.D.C.), obtaining dismissal of all FCPA and other criminal charges against our client.

Our representative matters include:

  • Obtained dismissal of all FCPA and conspiracy charges on behalf of client following a four-month trial in United States v. Goncalves, et al. (D.D.C.)
  • Obtained declination for a U.S. contractor in a DOJ investigation of contracts performed in Iraq.
  • Conducted an internal investigation for a U.S. manufacturer in regard to distributor relationships in Serbia and Slovenia.
  • Conducted internal investigations for a U.S. manufacturer of alleged improper payments in Southeast Asia and the Middle East.
  • Obtained declination of prosecution for insurance companies based in a U.S. territory in a DOJ investigation of financial transactions in Nigeria.
  • Conducted an internal investigation for a U.S. manufacturer in regard to distributor relationships in China.
  • Represented the CEO of a U.S. company relating to alleged improper payments in Eastern Europe.
  • Representing a former senior executive of a medical supplies company in DOJ and SEC investigations.