Foreign Corrupt Practices Act (FCPA)

The consequences of FCPA violations can include criminal convictions and millions in penalties. If you conduct business internationally, you need to identify your risk and maintain compliance programs that work.

We combine the resources of our International Trade and White Collar, Investigations and Compliance practices to assist clients with matters related to the FCPA and other international anti-corruption laws. We conduct risk assessments, and design and review compliance programs and internal control systems to detect―and avoid―potential violations. We train company personnel overseas and evaluate proposed business transactions and activities for compliance. When necessary, we undertake single-issue and comprehensive internal investigations and make recommendations regarding whether—and when—a voluntary disclosure to the government is appropriate.

Our attorneys represent companies and individuals in investigations and enforcement proceedings brought by the Department of Justice, individual U.S. Attorneys’ offices, and the Securities and Exchange Commission.

We also conduct due diligence FCPA compliance reviews as part of the mergers and acquisitions process and help clients evaluate and minimize successor liability risk.

Team Members
  • Conducted an intensive multi-country internal investigation for a major oilfield equipment company, including extensive document review, interviews and legal analysis. Subsequently, we represented this company in the SEC/DOJ settlement of payments alleged to be in violation of FCPA anti-bribery and accounting provisions. We also settled charges brought in the Netherlands in conjunction with local counsel.
  • Counseled and conducted an internal investigation for a major U.S. commodity importing distribution, and retail sales company regarding several FCPA matters. As part of this engagement, we conducted multiple training sessions and established an FCPA compliance system for the company. We continue to provide counseling and day-to-day advice.
  • Represented a European joint venture in an internal investigation of possible violations of the FCPA and money laundering statutes. The investigation was conducted in 30 jurisdictions, including the United States, Europe, Africa, and Asia.
  • Trained and counseled multiple large materials and industrial equipment manufacturing associations and their members on FCPA matters. As part of these engagements, we conducted FCPA training and coordinated best practices approaches for industry members.
  • Provided FCPA compliance training in India to more than 1,000 company personnel for a subsidiary of a U.S. IP company doing business there.
  • Advised multiple large companies regarding foreign subsidiary and foreign intermediary liability issues under the FCPA.
  • Counseled numerous publicly traded companies regarding FCPA due diligence in proposed mergers and acquisitions.
Most recent honors
View all for this practice