In the News

Ryan McConnell in Corporate Counsel: Many Fortune 500 Policies Unclear on Foreign 'Grease Payments'

Among Fortune 500 companies, only 19 of those with public codes of conduct prohibit their employees from making so-called "grease payments" to foreign officials. >>

Ryan McConnell in Corporate Counsel: TRACE Anti-Bribery Tool Tracks Corporate Gift-Giving

Is giving a bottle of wine a bribe? What if it goes to a government official in China? What if 10 more of your employees also gave the same official a nice gift while he was considering a contract with your company? A new anti-bribery tool from TRACE International, Inc. aims to keep corporate gifts on the up-and-up. >>



Recent Publications

Ethisphere Guest Article: Decoding FCPA Compliance: An Empirical Analysis

For in-house lawyers, the biggest news out of the UK this spring was not the royal nuptials of Kate and William, but the UK’s long awaited guidance on the UK Bribery Act. >>

Armor Holdings, Inc., Settles Foreign Corrupt Practices Act Claims with SEC, DOJ

Armor Holdings, Inc., recently resolved allegations that it violated both the anti-bribery and accounting provisions of the Foreign Corrupt Practices Act. Because of Armor’s extensive cooperation with the government, it was able to obtain a non-prosecution agreement from the Department of Justice and a settlement from the Securities and Exchange Commission. >>

Corporate Counsel Feature Article: Three Lessons From Enron in Dodd-Frank's Whistleblower Protection Framework

From Dodd-Frank to the UK phone hacking scandal, whistleblowers have captured the spotlight this summer. >>





Foreign Corrupt Practices Act

Employing our resources in white collar criminal defense, corporate securities, government contracting, mergers and acquisitions, and regulatory compliance, we regularly assist clients in complying with Foreign Corrupt Practices Act (“FCPA”) and other anti-corruption regulations. Our practice provides a comprehensive collection of services to address business corruption, including preventative counseling, investigative analysis, and representation in enforcement settings. We draw on our attorneys’ extensive experience in private practice and government service to advise clients, and we utilize our foreign offices in Latin America and the former Soviet Union to provide insight and assistance when appropriate.

  • We counsel domestic and foreign companies in technology, energy, and other industry sectors with respect to corruption issues that arise in operations and transactions worldwide, including Latin America, South America, Asia, the former Soviet Union, West Africa, and the Middle East.

  • We investigate allegations of corrupt payments and violations of accounting standards and advise clients on the legal implications of our findings.

  • We assist in the implementation and review of anti-corruption compliance programs, including internal corporate training, third-party due diligence, financial controls, and other risk mitigation measures.

  • We represent clients in civil and criminal proceedings brought by the SEC and the Department of Justice for alleged violations of the FCPA.

  • We counsel buyers and sellers in the transactional context to recognize and resolve FCPA issues and to implement risk mitigation measures.

  • We request on behalf of clients advisory opinions of the U.S. Department of Justice concerning compliance with the FCPA.