Sharie A. Brown

Partner

Washington, D.C.
Business Phone: 202.274.2874
Business Fax: 202.654.5602

sharie.brown@troutmansanders.com

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Sharie Brown is a recognized leader in ethics, compliance and internal investigations involving financial fraud and corruption for U.S. and non-U.S. companies, and non-profit organizations. As a former federal prosecutor, a Mobil Oil compliance and ethics officer, and a leader of white collar and compliance practices at major law firms, Sharie is regarded as a trusted advisor, counselor and skilled investigator for board audit committees, corporate senior management and general counsels in several regions of the world. Her experience, leadership and frequent media contributions regarding corporate fraud and corruption make her an international thought leader in the field.

As a partner in the White Collar & Government Investigations Practice Group of Troutman Sanders, Sharie represents international corporations and conducts internal investigations, audits and transactional due diligence worldwide in the areas of the Foreign Corrupt Practices Act (FCPA), including the Dodd-Frank whistleblower program, the UK Bribery Act, OFAC compliance and international trade controls, corporate ethics and compliance, World Bank procurement frauds, the Economic Espionage Act (EEA) and USA Patriot Act anti-money laundering. Sharie regularly represents U.S. and non-U.S. clients in complex matters involving the U.S. Department of Justice, the U.S. Department of Treasury, the U.S. Securities and Exchange Commission, the US Department of Commerce, the US State Department, U.S. Congressional Committees, and other local regulatory agencies.

Sharie’s compliance reviews, M&A due diligence and internal investigations have involved several industries in the following countries: the US, Canada, several industries in Mexico, Costa Rica, Panama, Venezuela, Brazil, the UK, France, Italy, Bulgaria, Bangladesh, Pakistan, the United Arab Emirates, Saudi Arabia, Kuwait, Egypt, Israel, Jordan, Ghana, Djibouti, Kenya, Tanzania, South Africa, Nigeria, Angola, the DRC, Equatorial Guinea, China, Thailand, India, Vietnam, Indonesia, Russia, and Kazakhstan, among others.

Prior to joining Troutman Sanders, Sharie chaired the White Collar Defense & Corporate Compliance Practice Group and the Foreign Corrupt Practices Act (FCPA), Anti-Corruption and Corporate Compliance Practice Group at two international law firms. Before joining these other law firms, Sharie worked at Mobil Oil Corporation’s Office of General Counsel, where she served as an ethics and compliance officer. In that capacity, she conducted internal investigations and developed a worldwide ethics and compliance program, a code of conduct and employee training videos, as well as pamphlets on the FCPA, and Iran, Iraq, Cuba and Libya sanctions compliance. As Mobil's policy advisor in Corporate Planning and Economics, she handled trade, tax and sanctions policy issues. In addition, she directed Mobil's state government relations in key states prior to her Corporate Planning assignment.

Prior to Mobil, Sharie was an Assistant United States Attorney in the Eastern District of Pennsylvania, where she handled tax, bank fraud and securities fraud cases. She was commended by FBI Director William Sessions for her co-prosecution of a securities fraud RICO, among other enforcement agency commendations. Sharie also clerked for the Honorable Richard M. Bilby, United States District Court, District of Arizona.

Sharie has authored, contributed to or been the feature of numerous articles regarding her practice areas, in publications such as the Wall Street Journal, the National Law Journal, Law360.com, and many others. She has also presented or moderated numerous FCPA, anti-corruption, anti-money laundering, compliance, and trade control panels all over the world, including the Middle East, Africa and Europe.

Sharie has been officially recognized by the Ethisphere Council and named to its list of 2009 Attorneys Who Matter in FCPA, which includes "the best and brightest in the legal field" who exemplify "the best public service, legal community engagement and academic involvement" and "help lead their companies to the top of the ethics and compliance world."

Publications & Featured Articles

  • Speaker, "Does a Defensible Anticorruption (or FCPA) Compliance Program Mean That It Is Understood In The Field," 2017 GRC Summit, June 5, 2017.

  • Presenter, "FCPA & Effective Third-Party Risk Management," ACI Houston Forum on the FCPA, February 2, 2017.

  • Co-Moderator, “Complying with US Sanctions in 2017,” DC Bar International Trade Committee, February 9, 2017.

  • Quoted, "Successor Liability in the Spotlight with Mondelēz's $13M FCPA Settlement After Purchase of Cadbury India," The FCPA Report, February 1, 2017. 

  • Quoted, "SEC, DOJ to Trim FCPA Enforcement in 2017," Agenda, January 17, 2017.

  • Author, "'Garden-Variety' Bribery Focus of FCPA Enforcement," Agenda, September 26, 2016.

  • Moderator, "Complying with U.S. Antiboycott Laws: What You Need to Know," Antiboycott Compliance Panel, March 23, 2016.

  • Quoted, "Scrutinizing hiring practices for FCPA violations," Compliance Week, March 15, 2016.

  • Quoted, “BYN Mellon Settlement Could Expand Scope of Foreign Bribery Law, Defense Lawyers Say,” Global Investigations Review, September 3, 2015.

  • Quoted, "BP spill fine: installments increasingly an option for hard-up defendants," Global Investigations Review, January 21, 2015.
  • Speaker, “The Russian/Ukraine Sanctions and Creating an Effective Compliance Program: What You Need to Know,” International Corporate Compliance Committee Program, New York State Bar Association, New York, NY, September 18, 2014.
  • Author, “11 Compliance Lessons Learned in Lagos, Nigeria,” Law360, June 27, 2014.
  • Author, "Why M&A Due Diligence Won't Prevent an FCPA Violation," Practicing Law Institute, Financial Services Industry Regulatory Compliance & Ethics Forum 2013 (October 29-30, 2013); Law360 (October 24, 2013) (Condensed).
  •  Featured source in "When and How Companies Should Include FCPA Risk Disclosures in SEC Filings (Part One of Three)." The FCPA Report, Vol. 2, No.9, September 26, 2013.
  • Author, “Ten Reasons Why Companies Should Value Their Compliance Officers,” Ethic Intelligence, August 6, 2013, and Law360, September 16, 2013.
  • Featured source in "A Guide to Disclosing Corruption Investigations in SEC Filings (Four Parts). " The FCPA Report, Vol. 2, No.9, May 1,2013; Vol. 2, No. 10, May 15,2013; Vol. 2, No. 11, May 29,2013; Vol. 2, No. 12, June 12, 2013.
  • Featured source in "Lax Indian Drug Approval Process Prompts Questions: Understaffing or Corruption?" Policy and Regulatory Report, May 23, 2012.
  • Featured source in "Conflicts Arise When Complying With U.S. and E.U. Laws," Corporate Counsel, February 22, 2012.
  • Featured source in "UK Anti-corruption Drive has US Companies Sweating," reuters.com, July 15, 2011.
  • "A Comment On Proposals For Reform Of The US Foreign Corrupt Practices Act: Criminal Successor Liability Restrictions," corporatecomplianceinsights.com, July 11, 2011.
  • "Companies Should Manage Impact of FCPA Probes on Key Stakeholders," The National Law Journal, June 6, 2011.
  • "Recommended FCPA Anticorruption Merger and Acquisition Due Diligence," FinancierWorldwide.com, April 2011.
  • Featured source in "FCPA Self-Reporting Still a Tough Sell," Law360.com, February 25, 2011.
  • Featured in "DLA Piper's Sharie Brown on the FCPA, UK Hype, and the Dark Empire," Corporate Crime Reporter, January 31, 2011.
  • Featured source in "The Uncomfortable Role of Chief Compliance Officer," CFOZone.com, June 25, 2010.
  • Featured source in "To Combat Overseas Bribery, Authorities Make It Personal," Wall Street Journal, October 8, 2009.
  • Featured source in "Lessons Learned From Latest FCPA Conviction," Compliance Week, October 2009.
  • "Identification of 'Red Flags' for Possible Violations of Key US Laws for Companies Operating Overseas," Corporate Compliance Insights, September 9, 2009.
  • "When is a Nigerian Local Tribe Leader a Foreign Official Under the FCPA?" WrageBlog, July 27, 2009.
  • "Doing More with Less: Effective Fraud Prevention in a Limited-Resources Environment," White-Collar Crime Fighter, Volume 11 No. 5, May 2009.
  • "Shortcuts on FCPA Due Diligence Today Will Be Costly Tomorrow," Guest Blog at White Collar Crime Prof Blog, March 3, 2009.
  • "Legal Issues: Maintaining Compliance During the Turmoil," financialexecutive magazine, March 2009.
  • "Crackdown on Corporate Corruption," Financier Worldwide, February 2009.
  • "Bracing For Increased Enforcement Against Corrupt Practices," Financier Worldwide, February 2009.
  • "US Foreign Corrupt Practices Act Some Reasons Why Compliance Programs Still Matter," Compliance Week, August 2008.
  • Featured source in "Bribery is too much like hard work," Financial Times.com, October 16, 2007.
  • "The Foreign Corrupt Practices Act and the Medical Device Industry," Thomson/West-Andrews Litigation Reporter, November 12, 2007.
  • Featured source in "FCPA Opinions on Hosting Foreign Officials," Compliance Week, October 16, 2007.
  • Featured source in "A New Dynamic in M&A Due Diligence," Financier Worldwide, December 2007.
  • "Practice Note: US Foreign Corrupt Practices Act Compliance Program Tips," Complinet, November 28, 2007.
  • "The Foreign Corrupt Practices Act and the Medical Device Industry," Andrews Litigation Reporter, Vol 14, November 12, 2007.
  • "Steps to an Effective Foreign Corrupt Practices Act Compliance Program," ABA Committee on Corporate Counsel Newsletter, Summer 2006 edition.

Presentations and Speaking Engagements

  • Panelist, "Banking on Anticorruption: The Multilateral Development Banks and the Fight Against Corruption in Development Financing in Asia," ABA International Law Fall Meeting, Tokyo, October, 2016.
  • Panelist, “Continuing Impacts of Ukraine-Related Sanctions on U.S. Industry in Russia,” International Law Forum, Women’s Bar Association Program, July 20, 2016. 
  • Moderator, "Compliance Risk Assessment Bootcamp – Strategies for Conducting an Effective Compliance Risk Assessment," Association of Corporate Counsel, June 3, 2016.
  • Panelist, “Cuba Legal and Policy Update 2016,” DC Bar International Trade Committee, May 25, 2016. 
  • Speaker, “Internal Investigations: “The Good, the Bad and the Ugly,” Pennsylvania Bar Association’s Embezzlement Webcast, April 7, 2016
  • Speaker, “Embezzlement 101,” Pennsylvania Bar Institute, Philadelphia, PA, April 7, 2016.
  • Speaker, “Africa Anti-Corruption Regulatory and Enforcement,” American Conference Institute’s FCPA Houston Boot Camp conference, Houston, TX, January 25, 2016.
  • Speaker, "Unfinished Laws: Dodd-Frank, JOBS & Other Acts," 2015 PLUS Annual Conference, November 11-13, 2015. 
  • Speaker, "U.S. Foreign Corrupt Practices Act ("FCPA") and Pharmaceutical Industry Compliance," Pharma Law Conference, February 5, 2015.
  • Speaker, “Connecting Compliance to Business Growth,” Thomson Reuters Compliance and Risk Summit, New York, NY, June 18, 2014.
  • Speaker, “The Future of FCPA: Has Your Risk Changed Since 2012?” Corporate Counsel’s 26th Annual General Counsel Conference, New York, NY, June 4, 2014.
  • Speaker, “Government Investigations on the Rise,” PLUS Southern California Chapter Seminar, Newport Beach, CA, April 17, 2014.
  • Speaker, “What Every Business Lawyer Needs to Know (and Law School Did Not Teach You) About the Risks to Clients and Their Attorney in an SEC Investigation,” ABA Business Law Section Spring Meeting, Los Angeles, CA, April, 10, 2014.
  • Moderator, “Regulatory, Compliance, and Risk Management: Foreign Corrupt Practices Act,” 18th Annual Corporate Counsel Institute, Washington, DC, March 13, 2014.
  • Speaker, “Defending the White Collar Case,” Pennsylvania Bar Institute, Philadelphia, PA, February 18, 2014.
  • Presenter “The US Foreign Corrupt Practices Act ("FCPA"): What Companies And Their Counsel Need to Know,” CLE, Troutman Sanders, Washington DC, September 5, 2013.
  • Presenter, “Case Study: HSBC Anti-Money Laundering and Sanctions Compliance,” International Congress on Anti-Money Laundering and Sanction, June 20, 2013.
  • Speaker, "How to Respond to a Dodd-Frank FCPA Whistleblower Letter: Initial Steps," TRACE International, May 6, 2013.
  • Featured in “Troutman Sanders Nabs Ex-DLA Piper FCPA Co-Chairwoman,” Law360, April 1, 2013.
  • Speaker, "Effective International Compliance In a Coordinated Enforcement Era," ABA Section International Law's Fall Meeting, Miami Beach, Florida, October 17, 2012.
  • Moderator, "How Can Global Ethics and Compliance Help Your Organization?," Global Outsourcing Association of Lawyers, September 11, 2012.
  • Speaker, "Your Complete Insiders Guide to Successfully Protesting Challenging Failed Bids," C5 Public Procurement in Sub-Saharan Africa, Capetown, South Africa, April 25, 2012.
  • Speaker, "Stranger in a Strange Land: Ethical and Compliance Challenges in International Disputes," ABA Section of Litigation Annual Conference, Washington, DC, April 20, 2012.
  • Speaker, "Law Firm Economics 101," Leadership Institute for Women of Color Attorneys, Atlanta, GA, March 22, 2012.
  • Speaker, "International Sanctions Compliance," Thomas Reuters 4th Compliance & Anti-Money Laundering Conference, Riyadh, Saudi Arabia, March 19, 2012.
  • Speaker, "Going Global: International Due Diligence and Other Matters," 16th Annual Corporate Counsel Institute, Washington, DC, March 9, 2012.
  • Speaker, "FCPA Merger & Acquisition Due Diligence Trends," PLI Financial Services Industry Regulatory Compliance & Ethics Forum, New York, November 2, 2011.
  • Speaker, "Anticorruption, Ethics and Corporate Compliance Trends: FCPA, UK Bribery Act, and OECD," Litigation Counsel of America’s Fall Conference and Induction of Fellows, Boston, October 13, 2011.
  • Speaker, "Third Party Vetting: How to Conduct Effective Risk-Based Due Diligence to Minimize Corruption and Bribery Exposure," C5 Anticorruption Forum – Sub-Saharan African Edition, Cape Town, South Africa, September 22, 2011.
  • Faculty Member, "Anticorruption and Bribery: A Compliance Workshop for Global Business Success," FTI Consulting and Deep Blue Energy, Dubai, United Arab Emirates, September 19-21, 2011.
  • Speaker, "FCPA Actions and New Compliance Guidelines: Are You Prepared?," Knowledge Group Webinar, August 25, 2011.
  • Speaker, "Anti-Corruption Due Diligence in M&A Deals in Emerging Markets," TRACE International Webinar, June 2, 2011.
  • Speaker, "International Compliance: Protecting Against Money Laundering, Bribery, and Other Activities Implicating FCPA, AML, BSA, OFAC," ACI Conference, New York, May 6, 2011.
  • Speaker, "FCPA, Antibribery Trends & Related Compliance Solutions," Kuwait Anticorruption Seminar, Kuwait City, Kuwait, April 5, 2011.
  • Speaker, "Facing the Music – How to Deal with the DOJ and Shareholders Over FCPA Violations," Dow Jones Global Compliance Symposium, Washington, DC, March 31, 2011.
  • Speaker, "Negotiating in the Shadow of the FCPA," Business Development Academy Live Webinar, March 24, 2011.
  • Speaker, "Enforcement, The Sequel: Raids, Special Ops, and Undercover Miles at Your Doorstep," MCCA Conference, Chicago, March 16, 2011.
  • Speaker, "How to Pay a Bribe: Lessons in Circumventing Internal Controls," TRACE International, Washington, DC, October 20, 2010.
  • Speaker, "FCPA Compliance," 2010 TransPerfect Legal Solutions FCPA Luncheon, New York, October 14, 2010.
  • Speaker, "Transition Your Legal Career: Transition Strategies for Today's Lawyer," Corporate Counsel Women of Color 6th Annual Career Strategies Conference, New York, October 7, 2010.
  • Speaker, "Corporate Investigations - FCPA Compliance and India," US-India Business Legal Services Executive Committee Seminar, New Delhi, India, September 24, 2010.
  • Speaker, "Compliance with the US Foreign Corrupt Practices Act and Required Due Diligence During Mergers & Acquisitions," 56th Annual Rocky Mountain Mineral Law Institute, Banff, Alberta, Canada, July 22, 2010.
  • Speaker, "Governance Implications of the FCPA Surge for Boards and Corporate Counsel," PLI Corporate Governance 2010 - A Master Class, New York, February 17, 2010.
  • Speaker, "Emerging Markets – Opportunities, Challenges and Obligations," Dow Jones/Ethisphere Global Ethics Summit panel, New York, February 23-24, 2010.
  • Speaker, "Conducting Pre-Transactional Anticorruption Due Diligence Including Pre-Merger/Pre-IPO," C5 European Forum on Anticorruption, Frankfurt, Germany, January 26-27, 2010.
  • Speaker, "FCPA Enforcement – A Year in Review and Future Trends," Bloomberg Law FCPA Conference, New York, December 17, 2009.
  • Speaker, "Foreign Corrupt Practices Act," Practising Law Institute's Financial Services Industry Regulatory Compliance & Ethics Forum, New York, November 11, 2009.
  • Speaker, "Women Doing Business Overseas," National Association of Women Lawyers Fifth Annual General Counsel Institute, New York, November 6, 2009.
  • Speaker, "Out of Sight But Not Out of Mind - Ensuring FCPA Compliance When Using Third-Party Agents, Representatives and Distributors," at the PLI Conference High Tech - High Risk: Foreign Corrupt Practices Act Implications for Technology Companies, Santa Clara, California, September 17, 2009.
  • Speaker, "FCPA, Antiboycott and Export Regimes," IPOA Conference on Export Controls for Defense Service Providers, Washington, DC, September 2, 2009.
  • Faculty Member, Two-Day Training Programme on Bribery and Corruption: Avoiding the Pitfalls in a Global Economy, Lagos, Nigeria, July 13-14 and 16-17, 2009.
  • Moderator, Anti-Corruption, Spotlight on Enforcement of the Foreign Corrupt Practices Act (FCPA) in Europe, Paris, September 29-30, 2009.
  • Moderator, Dow Jones/Ethisphere Global Ethics Summit, Asia Challenges panel and Managing Third Parties Around the World panel, New York, February 4-5, 2009.
  • Presenter, General Counsel Roundtable, "Financial Crisis: Going from Survival to Success in Difficult Times," Strategies for Expected Fraud and Corruption Enforcement in 2009, Chicago, February 19-20, 2009.
  • Moderator, Georgetown Corporate Counsel Institute, FCPA Anticorruption panel, Washington, DC, March 12-13, 2009.

Appointments

  • Board of Overseers, University of Pennsylvania, School of Arts & Sciences, June 2016-present
  • The Ethisphere-Corpedia Joint Committee on Government and Business Ethics.
  • Sanctions Subcommittee of the US Department of State’s Advisory Committee on International Economic Policy.

Professional and Community Involvement

  • Fellow, American Bar Foundation
  • Chair of the DC Bar’s International Trade Committee, International Law Section, 2015-present
  • Georgetown Corporate Counsel Institute, Co-Chair of the Advisory Board Program Planning Committee
  • ABA International Anticorruption Committee
  • ABA International Anti-Money Laundering Committee
  • International Bar Association
  • National Foreign Trade Council (NFTC)
  • USA*Engage

Rankings and Recognition

  • Selected to National Black Lawyers- Top 100 professional honorary organization, (2015-2016).
  • Recognized among, 2015 Elite White Collar Crime Lawyers, the Legal 2015 Awards, Corporate LiveWire.
  • Recognized among, Attorneys Who Matter in FCPA, Ethisphere Council, July 2009.
  • Honored as a Distinguished Attorney by the National Bar Association's Greater Washington Area Chapter Women Lawyers Division, May 2009 Annual Networking Reception.
  • Fellow, Litigation Counsel of America, 2009-present.

Professional Experience

  • Partner, Troutman Sanders LLP, 2013-present
  • Partner, DLA Piper LLP, 2009-2013
  • Partner, Foley & Lardner LLP, 2000-2008
  • Various positions with office of General Counsel, Mobil Oil Corporation, 1988-2000
  • Assistant US Attorney, US Attorney’s Office, Eastern District of Pennsylvania, 1984-1988
  • Associate, Peabody Lambert & Meyers, 1983-1984
  • Law Clerk to the Honorable Richard M. Bilby, United States District Court, District of Arizona, 1982-1983

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Education

  • Georgetown University Law Center, J.D., 1982
    Dean's List
  • University of Pennsylvania, joint B.A./M.A., 1979
    ONYX Senior Honor Society, Pi Sigma Alpha Honor Society, Sphinx Honor Society

Bar Admissions

  • District of Columbia
  • Pennsylvania

Court Admissions

  • Supreme Court of the United States