Foreign Corrupt Practices Act

The U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) are enforcing the U.S. Foreign Corrupt Practices Act (FCPA) anti-bribery law more aggressively than ever. These actions against U.S. and non-U.S. companies and individuals have set the pace for anti-corruption prosecutors across Europe, Asia and the Middle East, and around the world.

Our White Collar and Government Investigations lawyers provide nationally recognized FCPA legal services and global FCPA and anti-corruption investigative experience to our clients. We focus on the delivery of comprehensive, results-oriented FCPA enforcement prevention, risk mitigation, and defense solutions.

We provide the following services, among others:

  • Representation and defense of U.S. and non-U.S. companies and international entities before the DOJ, SEC and other government agencies, in connection with FCPA and related anti-bribery matters, as well as whistleblower complaints under the Dodd-Frank Wall Street Reform and Consumer Protection Act
  • Representation during agency disclosures
  • Third-party and merger and acquisition-related (M&A) anti-bribery due diligence reviews and opinions, and related DOJ and SEC representations
  • FCPA and international anti-bribery compliance risk assessments, audits, reviews, and employee training
  • FCPA, UK Bribery Act and international anti-bribery compliance program design and policy drafting
  • Preparation of FCPA and international anti-bribery contract terms, representations and warranties, and certifications
  • Representation in parallel anti-corruption enforcement actions and congressional investigations, including World Bank anti-corruption procurement proceedings

Representative Experience

  • Conducted internal investigations of suspected violations of the FCPA, UK Bribery Act or other anti-bribery laws for U.S. and non-U.S. companies in the energy, transportation, engineering, telecom and pharmaceuticals sectors
  • Defended U.S. clients in FCPA enforcement matters, including Dodd-Frank whistleblower matters, before the DOJ and SEC and other government agencies
  • Represented a non-U.S., state-owned entity before the DOJ and SEC with respect to FCPA enforcement issues.
  • Conducting multi-country FCPA and UK Bribery Act corporate compliance risk assessments and audits
  • Drafted FCPA and global anti-corruption compliance policies and procedures, conducted FCPA and anti-corruption due diligence of third-party agents, and performed related M&A due diligence
  • Represented clients on FCPA disclosures before the DOJ and SEC
  • Reviewed the lawfulness of expediting payments in a Middle East country under the FCPA
  • Provided opinions on security payments to police in a country with an emerging economy
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