Services

Global Anti-Corruption/FCPA Compliance and Investigations

We are global anti-corruption counsel to multiple Fortune 500 companies as well as many other public, private and nonprofit entities in a variety of sectors including medical devices, healthcare, healthcare IT, biotech, manufacturing, logistics, media, technology and retail. We offer extensive experience, demonstrated capabilities, established credibility with government enforcers and proven global reach. Our Washington, DC-based team members have proximity to and interact regularly with key enforcement agencies, yet we provide exceptional cost efficiency because many of our team members are based in the lower-cost Nashville, Tennessee market.

We have assisted clients regarding business transactions and investigations throughout the world including: China, India, Italy, Brazil, Mexico, Nigeria, Germany, Cambodia, Belgium, Greece, Thailand, Morocco, Singapore, Sweden, Turkey, Canada, Libya, Russia, Argentina, Australia and the United Arab Emirates, among other countries. Through our firm’s membership in Lex Mundi and State Capital Group, two of the world’s leading associations of independent law firms, our attorneys have ready access to local counsel and resources in 120 countries.

Our attorneys are recognized for their anti-corruption and international investigations experience and are frequently called upon by organizations such as the American Bar Association, the Association of Corporate Counsel, American Health Lawyers Association, AdvaMed, Lex Mundi and the International Law Office (ILO) to address domestic and international audiences. Our team includes a former Assistant Chief of the U.S. Department of Justice’s Fraud Section, Criminal Division, who has represented a number of companies on FCPA issues, as well as a former federal prosecutor and Federal Bureau of Investigation (FBI) agent with experience working on FCPA matters for the U.S. Department of Justice and experience serving as an Organisation for Economic Co-operation and Development (OECD) anti-corruption monitor team member and advisor to foreign authorities on anti-corruption enforcement.

Services include:
  • Conducting international anti-corruption investigations in Africa, Asia, Europe, Mexico, Latin America, and the Middle East;
  • Conducting anti-corruption risk assessments;
  • Designing, reviewing and implementing cost-effective anti-corruption compliance policies, procedures and internal controls;
  • Conducting international due diligence on third parties;
  • Navigating anti-corruption compliance issues in international mergers, acquisitions, joint ventures, sourcing, contracting, distributing and sales;
  • Assisting clients in drafting anti-corruption contractual language for agents, distributors, and other third parties; and
  • Conducting anti-corruption training for corporate clients and their employees, agents, and third party business partners.

Representative Engagements
  • Conduct global compliance risk assessment, with focus on FCPA issues, for a global medical device company.
  • Internal investigation and business partner assessment for a global medical device company in Turkey. 
  • Internal investigation for a large private company in China (including Hong Kong), Singapore, Cambodia and Thailand.
  • Internal investigation for public company in Africa and Europe.
  • Internal investigation for Fortune 500 company related to Chinese joint venture.
  • Due diligence investigation for Fortune 500 company regarding prospective African acquisition.
  • Internal investigation for public company related to activities in India.
  • Internal investigation for public company related to activities in China.
  • Representation of Fortune 500 company related to activities in Latin America.
  • Due diligence investigation for a large publicly traded company related to activities in the United Arab Emirates.
  • Representation of public company regarding FCPA compliance for international operations (South America, Australia and Europe).
  • Representation of Fortune 500 company related to anti-corruption compliance integration of European acquisition.
  • Development of anti-corruption compliance programs for multiple Fortune 500 and private companies.

Presentations
  • Institute of Internal Auditors' Fraud Conference on FCPA and Anti-Corruption Matters, October 9, 2012.
  • "FCPA - Keeping Your Board on the Straight and Narrow," 9th Annual Boardroom Summit, October 4-5, 2012.
  • "Beware of the 'Practical' Advice: Global Migration Counsel and International Anti-Bribery Statutes," AILA's 2012 Annual Conference on Immigration Law, June 13, 2012.
  • "How to Implement Effective Internal Controls to Prevent Corrupt Behavior and Minimize the Risks of Third Party Bribes in Foreign Clinical Research," 6th Annual Conference on FCPA and Anti-Corruption for the Life Sciences Industry, May 9, 2012.
  • "FCPA, UK Bribery Act, and Anti-Corruption Job Opportunities: What Young Lawyers Need to Know," ABA YLD 2012 Spring Conference, May, 4, 2012.
  • "Structuring or Revamping Your Compliance Program," ACC Compliance and Ethics Training Program, May 1, 2012.
  • "Global Trends in Litigation," Association of Corporate Counsel meeting, New York, NY, December 1, 2011.
  • "Hot Topics in Healthcare: Privacy, Antitrust and Fraud," Webinar, December 2011.
  • "Anti-Corruption Regulation in the Middle East," Lex Mundi Regional Conference, Dubai, UAE, October 29, 2011.
  • "When the Authorities Come Calling: Responding to U.S. and International Investigations and Complying with Foreign Anti-Corruption Laws," Southern Law Network 12th Annual General Counsel's Forum, The Greenbrier, WV, October 29, 2011.
  • "External Investigations and Emerging Investigation & Enforcement Issues," Lex Mundi Business Crimes & Compliance Group Global Meeting, London, UK, September 30, 2011.
  • "Business Crimes and Compliance 2011 Update - Key U.S. and International Risk Management Developments," Lex Mundi Webcast, August 31, 2011.
  • "Practical Tips for Handling International Investigations & Anti-Corruption Compliance," Association of Corporate Counsel Webcast, July 20, 2011.
  • "A Primer on Foreign Corrupt Practices Act and Anti-Corruption Issues for Healthcare and Life Science Companies, Part III: Defensive Strategies in Conducting an FCPA Compliance Investigation and Responding to a Government Inquiry," American Health Lawyers Association webinar, July 14, 2011.
  • "Conducting Cross-Border Investigations," 2011 Global Counsel Congress, New York, NY, June 16, 2011.
  • "Legislative Hot Topics," Compliance in Action: Ethics and Compliance Issues for In-House Counsel in the Energy Sector, Houston, TX, June 9, 2011.
  • "A Primer on Foreign Corrupt Practices Act and Anti-Corruption Issues for Healthcare and Life Science Companies, Part II: Establishing Compliance Controls to Minimize FCPA and Anti-Corruption Risks for Healthcare and Life Science Companies," American Health Lawyers Association webinar, June 1, 2011.
  • "A Primer on Foreign Corrupt Practices Act and Anti-Corruption Issues for Healthcare and Life Science Companies, Part I: FCPA and Anti-Corruption 101 for Healthcare and Life Science Companies," American Health Lawyers Association webinar, May 11, 2011.
  • "Heading off Trouble or Stopping in its Tracks: Conducting Internal Investigations and Minimizing False Claims Act and Foreign Corrupt Practices Act Risks," Wyche In-House Counsel Roundtable, Greenville, SC, May 4, 2011.
  • "Overseas Efforts to Curb Public Corruption," Bulletproof Blog webcast, April 14, 2011.
  • "FCPA: Critical Issues and Best Practices for Life Sciences Companies," Web Seminar, April 14, 2011.
  • "Minimizing FCPA Risk when Conducting Clinical Trials Abroad at State-Run Hospitals and Trial Sites," Managing Legal and Regulatory Risks in Structuring and Conducting Clinical Trials, American Conference Institute, Philadelphia, PA, January 2011.
  • "Anti-Corruption Policy and Practice Update 2010," Lex Mundi webinar, October 21, 2010.
  • "Foreign Anti-Corruption Enforcement: How Recent OECD Developments Affect Your Risk & Compliance Obligations," Association of Corporate Counsel webcast, June 1, 2010.
  • "Preparing for Shifting FCPA Enforcement Trends and New Government Investigation Techniques in the Life Sciences Industry," American Conference Institute, New York, NY, May 2010.
  • "The FCPA Effect: What Escalating Enforcement of the U.S. Foreign Corrupt Practices Act Means for Companies & Individuals Involved in International Business," The Corporate Governance Center at the University of Tennessee, Knoxville, TN, April 16, 2010.
  • "FCPA: The Critical Issues Facing the Medical Device and Pharmaceutical Industries," KPMG ShareForum, Washington, DC, March 2010.
  • "The Foreign Corrupt Practices Act in the Health Care Industry," audio conference, Health Ethics Trust, Washington, DC, March 2010.
  • "The U.S. Foreign Corrupt Practices Act (FCPA) and more: What In-House Counsel Need to Know," Legal Talk Network In-House Legal podcast, March 2010.
  • "Overview of the U.S. Foreign Corrupt Practices Act," Lex Mundi Business Crimes & Compliance Committee Meeting, Paris, France, October 15-16, 2009.
  • "FCPA And Best Practices in Preventing Fraud and Corruption in a Global Business," Association of Corporate Counsel webcast, September 24, 2009.
  • "The Foreign Corrupt Practices Act: What Counsel for Every Business that Operates Internationally Needs to Know," Plenary Session Presentation, Lex Mundi North American Regional Conference, May 28, 2009.
  • "FCPA Overview," General Counsels' Forum, Nashville, TN, May 5, 2009.
  • "FCPA Compliance: What You Don't Know Can Hurt You," AdvaMed Conference, national web seminar, April 2009.

Publications


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