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’s recent representations include:

• A Fortune 100 company in an SEC investigation into FCPA whistleblower allegations in Kazakhstan.  
• Smith & Nephew plc and Smith & Nephew Inc. in a joint DOJ/SEC investigation of FCPA issues related to the sale of medical devices. 
• A Fortune 100 public company in an SEC investigation of goodwill accounting for a recent acquisition.
• A Fortune 100 company under investigation by Brazilian law enforcement involving allegations of anti-competitive and corrupt conduct. 
• Individuals, including a former employee of a major U.S. investment bank, in an FCPA investigation.
• A Fortune 100 company in a joint DOJ/SEC inquiry involving accounting fraud in China.
• A major pharmaceutical company in an economic sanctions investigation relating to sales to Iran.
• Novo Nordisk in a joint DOJ/SEC investigation of FCPA issues related to the Iraq Oil for Food Program.

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.

Leslie also regularly conducts anti-corruption due diligence for mergers and acquisitions and joint venture arrangements. Clients routinely invite her to conduct training courses on the ever-changing FCPA landscape. Leslie’s recent experience includes:

• Comprehensive anti-corruption risk assessment of a major U.S. public company.
• M&A due diligence involving a multi-billion dollar acquisition of a company under investigation by DOJ/SEC for potential FCPA violations.    
• On the ground due diligence review of a third-party intermediary in Azerbaijan for Fortune 100 company.   
• Detailed compliance counseling to a major pharmaceutical company concerning FCPA risks involved in international grant programs.

Leslie also represents corporate and individual clients in other international law enforcement matters, including money-laundering proceedings, economic sanctions matters and embargoes. 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. 

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.

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.