Marilyn Batonga

Marilyn Batonga

Baker & McKenzie LLP


A. Marilyn Batonga represents domestic and international corporate clients in a broad range of compliance and dispute resolution matters, including criminal investigations by the US Department of Justice, the US Securities and Exchange Commission, and other government agencies. She advises clients on the design and implementation of compliance programs and performs due diligence on high-risk business transactions.

Practice Focus

Marilyn focuses her practice on matters related to anti-corruption, fraud, and corporate compliance. She helps companies effectively and efficiently identify and address legal compliance risk around the world, particularly in emerging markets and high-risk jurisdictions.

Marilyn has significant experience handling Foreign Corrupt Practices Act (FCPA) investigations, whistleblower matters, merger and acquisition due diligence, compliance risk assessments, and compliance program development. Marilyn's work also routinely involves advising government contractors in connection with U.S. False Claims Act compliance.

She regularly provides training to corporate legal and HR departments on these matters, as well as on the art and science of conducting internal investigations.

Marilyn routinely writes and speaks on compliance trends, corruption, and doing business in emerging markets.

She is also a contributor to Baker McKenzie’s Francophone Africa Newsletter, which is a monthly review of legal developments that affect business operations in the region written in French and English.

Marilyn has been recognized for her pro bono work, which involves the representation of minors in immigration and family court proceedings.

Representative Legal Matters

  • Managing and conducting a full-scale internal investigation on behalf of a provider of aviation services in connection with potential violations of procurement rules and anti-corruption laws in South Africa.

  • Advising a consulting firm in connection with allegations of misconduct and state capture in South Africa.

  • Managed and conducted an internal investigation into allegations regarding the use of prison labor by a Chinese sub-contractor for a major US retailer.

  • Conducted a review of third-party relationships in Saudi Arabia, Brazil, China, Russia, India and Mexico for a large pharmaceutical company.

  • Conducted an internal investigation on behalf of multinational manufacturing company in connection with whistleblower allegations of improper payments made by a distributor in Morocco.

  • Assisted in an internal investigation on behalf of a multinational software company on potential violations of the FCPA in South Africa.

  • Conducted anti-corruption due diligence on target companies in cross-border mergers and acquisitions, and joint venture partners in international joint ventures.

  • Conducted internal investigations into allegations of off-label promotion and violations of internal policies for a large pharmaceutical company.

  • Conducted anti-corruption due diligence on third-parties in, among other jurisdictions, Sierra Leone, Egypt, Peru, Angola, Bangladesh and Nigeria.

  • Assisted in an internal investigation into allegations of money laundering in Argentina for a major car manufacturer.


  • District of Columbia~United States (2017)
  • U.S. District Court, Southern District of New York~United States (2014)
  • U.S. District Court, Eastern District of New York~United States (2014)
  • New York~United States (2013)


  • Columbia Law School, United States (J.D., Harlan Fiske Stone Scholar) (2012)
  • Swarthmore College (B.A., Dean's Award) (2008)


  • English
  • French
  • Spanish



  • Panelist, Hot Topics in Immigration and International Issues in the Time of Biden, 96th Annual Convention of the National Bar Association, July 2021

  • Speaker, The Supply Chain Companies You Keep – practical considerations for efficiently managing growing third party legal risk, 2021 Annual Supply Chain Risks & Rewards in Emerging Markets Conference, April 2021