Charles S. Leeper

Charlie represents companies and individuals in investigations and prosecutions of alleged Foreign Corrupt Practices Act (FCPA) violations. He also regularly advises companies on FCPA compliance matters and provide assistance in designing due diligence, certification and training protocols.

These engagements 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.).
• Represented 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 Middle East.
• Conducted an internal investigation for a U.S. beverage producer of invoicing and sales agent practices in Syria.
• Represented insurance companies based in a U.S. Territory in a DOJ investigation of financial transactions in Nigeria.

Charlie has represented clients from diverse industries in investigations conducted by authorities in the United States, Canada, and the European Union. He defends companies and individuals, domiciled in the U.S. and in other countries, against allegations of bid-rigging, price-fixing, market or customer allocation, and other forms of alleged anticompetitive conduct. We have handled all phases of antitrust investigations and prosecutions, including representing clients at trial.

These engagements include:

• Represented companies at trial and successful appeal in which government alleged bid-rigging on construction projects financed by the U.S. Agency for International Development. United States v. Anderson, et al. (D.D.C.)
• Conducted an internal investigation for a drilling services company of suspected of bid-rigging and represented company it in a voluntary disclosure to competition authorities in Europe.
• Secured declination of prosecution on behalf of an executive in an Antitrust Division price-fixing investigation of the helicopter transport services industry. (N.D. Tex.)
• Secured declination of prosecution on behalf of the former CEO of a joint venture in an Antitrust Division price-fixing investigation of the elastomers industry. (N.D. Cal.)
• Represented an airline executive in a DOJ investigation of pricing in the air cargo industry. (D.D.C.)
• Obtained declination of prosecution for European sales executives in an investigation of alleged conspiracy to fix prices and allocate customers in the vitamins industry. (N.D. Cal.).

Charlie has extensive experience representing government contractors and their employees in criminal investigations and related civil proceedings involving allegations of procurement fraud.

These engagements include:

• Represented a non-U.S. contractor in a DOJ investigation of alleged kickbacks on contracts awarded by the U.S. Department of Defense for reconstruction work in Iraq.
• Obtained declination of prosecution for computer manufacturers in DOJ investigations of procurements by the FBI and the DEA.
• Obtained declination of prosecution for prime contractor on construction of federal courthouses in New York and Nevada in connection with investigation of alleged bribes and kickbacks.

Charlie has obtained decisions from the Criminal Division of the Department of Justice, and the U.S. Securities and Exchange Commission, to decline prosecution and/or the commencement of enforcement action in securities fraud investigations of numerous clients. He has achieved this success for clients such as:

• A publicly traded reinsurer in connection with allegations of insider trading
• Partners and associates in a major law firm in connection with DOJ and SEC investigations of off-balance sheet entities used by Enron
• Sales and marketing executives in connection with parallel criminal and civil investigations arising out of alleged improper revenue recognition in the internet services industry
• The CFO of a major hedge fund in connection with DOJ and SEC investigations of alleged failure to disclose beneficial ownership of publicly traded securities.