Deferred prosecution - Conducted an internal investigation, designed worldwide FCPA training and created a remediation plan for a leading energy construction and engineering services company under investigation for allegedly paying millions in bribes to foreign officials in South America and Africa. As a result, we persuaded the US government that our client’s complete cooperation, swift handling of non-compliance employees and dedication to instituting remedial action warranted a deferred prosecution agreement.
Successful joint venture - Conducted FCPA and trade sanctions due diligence, drafted protective contractual language and developed compliance policies and procedures that enabled a US public company to proceed with its proposed joint venture with a Chinese state-owned entity. We also trained the joint venture partner’s Chinese legal and business teams on US anti-corruption and trade sanction laws to prevent future liability.
Comprehensive compliance program -
Revised a global consulting company’s anti-bribery program, rewrote its code of conduct, trained management on new gift-giving policies, restructured the compliance department and educated the board of directors on liability as part of a 360-degree review of the company’s compliance program encompassing 120 countries. By identifying areas of vulnerability, prioritizing risk and developing strategies to address them, we helped reduce the likelihood of government investigations and reputational damage.
No FCPA charges
- Conducted an internal investigation, helped terminate non-compliant employees and revised product distribution agreements for a Fortune 500 IT company under investigation for public procurement fraud and bribery in Brazil. As a result of the client’s implementation of our comprehensive remediation plan, DOJ decided not to file charges.
Quick, credible investigation
- Collected 3.5 million documents and interviewed 120 witnesses in the US, Australia, the Middle East and Asia in a large-scale internal investigation of a Fortune 100 metals company facing FCPA-related charges. Our ability to execute the investigative plan quickly and earn the trust of US government authorities with our thoroughness and transparency saved the client significant time and money.