FCPA/Anti-bribery
The firm has extensive experience representing clients with respect to the U.S. Foreign Corrupt Practices Act (FCPA). Our lawyers are also well-versed in laws that relate to dealing with government officials and government authorities in various countries.
Our practice includes creating and implementing compliance programs for clients, counseling clients on compliance issues that arise from international sales and marketing activities, conducting internal investigations and defending clients in the course of Securities and Exchange Commission (SEC) and Department of Justice proceedings. Our lawyers who practice in this area include a former Associate Director of the Enforcement Division of the SEC who, for five years, had principal responsibility for FCPA investigations undertaken by the Commission, and a former Deputy Chief of the Fraud Section in the Criminal Division of the Department of Justice, which is the Section responsible for FCPA enforcement.
In recent years, the firm has been involved in various FCPA matters involving corporate activities in more than 80 countries. Our clients in this area include, among others, Fortune 500 companies in the pharmaceutical, healthcare, defense, aerospace, energy, transportation, advertising, high-tech, telecommunications, insurance, food products, and manufacturing industries, as well as leading investment banks and other financial institutions.
For many of our clients, our FCPA services have included drafting compliance policies, assisting in establishing due diligence procedures for evaluating compliance by representatives and consultants, and developing in-house training. We are also frequently involved in conducting due diligence on FCPA issues for clients in connection with mergers, acquisitions, and joint ventures involving international sales and business operations. For other clients, we have been asked to conduct internal FCPA investigations and, at times, to review internal investigations performed by others.
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