Leslie A. Shubert

LESLIE SHUBERT is a member of the firm’s global FCPA/Anti-Corruption practice and represents individuals and corporations in both civil and criminal investigative proceedings and enforcement actions. Leslie represents clients before law enforcement and regulatory agencies, including the Department of Justice and the Securities and Exchange Commission, and has significant experience advising clients regarding the Foreign Corrupt Practices Act (FCPA). She has conducted numerous internal investigations throughout the United States, as well as in Asia, Europe, South America and Africa. She represents a wide variety of clients from across the major industries that have been the primary focus of FCPA enforcement activity in recent years, including pharmaceuticals, medical devices, manufacturing, energy, consumer products, and financial services.

Leslie also represents corporate and individual clients in other international law enforcement and internal investigation matters, including antitrust, accounting fraud, money-laundering proceedings, and economic sanctions matters. In civil practice, she has participated in complex civil matters involving antitrust, securities, professional liability, and telecommunications law. She also has advised clients regarding effective internal investigation techniques and document retention practices to minimize litigation risk.

In addition to representing clients in internal and external investigations, Leslie has developed and helped implement numerous global compliance programs and policies. She also has extensive experience conducting compliance risk assessments for clients, which involve testing existing compliance structures and recommending state of the art program enhancements.

Prior to joining Sidley, Leslie worked in the United States Attorney’s Office for the District of Columbia in 1997 and previously served as a legislative assistant to Congressman Ralph Regula.

Leslie’s recent representations include:

• Securing a resolution on behalf of a U.S. public company in the aviation industry. This was a coordinated resolution with the DOJ and U.S. Securities and Exchange Commission (SEC), also involving the UK Serious Fraud Office — in connection with bribery allegations, including alleged violations of the U.S. Foreign Corrupt Practices Act (FCPA), in Nepal and South Africa.
• Representing a large agricultural company in an antitrust investigation involving allegations of price fixing in front of the DOJ and multiple state AG offices.
• Securing a resolution on behalf of a U.S. public company in the waste management industry. This was a coordinated resolution with the DOJ, U.S. Securities and Exchange Commission (SEC), as well as Brazilian authorities — including the Comptroller General’s Office (CGU), the Attorney General’s Office (AGU), and the Public Prosecutor’s Office (MPF) — in connection with bribery allegations, including alleged violations of the U.S. Foreign Corrupt Practices Act (FCPA), in Brazil, Mexico, and Argentina.
• Securing a declination for a nuclear power company in an SEC investigation into its overseas operations and alleged project cost overruns and bribery concerns.
• A natural gas company in an internal investigation involving FCPA allegations related to the potential hiring of relatives of government officials in order to assist the company in retaining or obtaining business.
• A multinational gambling company in investigations into FCPA violations in Brazil, lottery fraud in Italy, and accounting fraud.
• Securing a resolution on behalf of a multinational home products producer in an accounting fraud investigation into its business in Mexico.
• A Fortune 50 life sciences company in multiple investigations into FCPA, accounting fraud, conflict of interest, and health care compliance concerns.
• A medical device manufacturing in an internal investigation involving allegations of accounting fraud in China.
• Global compliance risk assessment for large state-owned Middle East energy company.
• Global FCPA compliance review and risk assessment for a major public company that does business in 21 countries around the world.
• Comprehensive anti-corruption risk assessment of a major U.S. public company.
• Policy program and compliance risk advice to a major standards-setting company.
• M&A due diligence involving a multibillion dollar acquisition of a company under investigation by DOJ/SEC for potential FCPA violations.
• Advice to an international equipment manufacturer regarding economic sanctions compliance risk in connection with an international reorganization.
• On the ground due diligence review of a third-party intermediary in Azerbaijan for Fortune 100 company.

Leveraging her knowledge, Leslie provides compliance counseling to an international non-profit organization that supplies African farmers with financing and training to reduce hunger and poverty.