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Anti-Corruption

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In this climate of increased regulation and intensified enforcement, clients turn to Arnold & Porter Kaye Scholer for our insights and extensive experience in global anti-corruption investigations, defense, and compliance matters. With an experienced team of former high-level prosecutors and lawyers from the DOJ, SEC, Department of Homeland Security, and US Attorneys' Offices, as well as the UK's Serious Fraud Office, we vigorously defend companies and individuals by anticipating and strategically responding to government investigations and enforcement actions under the US Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and other anti-bribery laws and regulations. We also conduct internal investigations in response to potential corruption issues around the world.

We have represented global leaders in diverse industries that span electronics, pharmaceuticals, media, cosmetics, financial services, defense and aerospace, hospitality, retail, medical equipment, energy, chemicals, and insurance. Our clients' operations have taken us to more than 85 countries, and we have established relationships with local counsel should issues arise under a host country's law.

We also work with clients to minimize exposure by tailoring compliance programs to the specific cultural, structural, and systemic activities of the organization. Our experience covers risk reviews, development of company policies to mitigate risks, and training for legal departments and business employees. We work with both domestic and foreign companies, including designing programs and training for non-US locations.

Representative Matters

  • Fortune 500 telecommunications company in connection with an FCPA investigation involving company's efforts to win contracts in China, Europe, the Middle East, and Central America. Successfully handled company's cooperation with the DOJ and SEC, leading to declination from the DOJ.
  • Multi-national media company in ongoing UK and US criminal investigations and proceedings.
  • German-based firearms manufacturer in ongoing FCPA investigation being conducted by the DOJ regarding allegations of bribe payments to Indian government officials in efforts to win government contracts.
  • Large computer contractor in connection with a sprawling FCPA investigation involving company's activity in India.
  • South African financial institution in FCPA investigation involving alleged bribery in connection with a tender to provide payment services to South African social grant beneficiaries. Coordinating company's cooperation with the DOJ and the SEC.
  • Major European insurance company in an FCPA investigation involving alleged bribery to win contracts in Indonesia. Successfully handled company's cooperation with the DOJ and SEC, leading to declination from the DOJ and a favorable settlement with the SEC.
  • Publicly traded private equity firm in connection with an FCPA investigation involving allegations of bribery by the firm's portfolio company as part of an effort to win contracts in Romania and Columbia.
  • Multiple employees of a major financial institution in connection with ongoing DOJ and SEC investigation into the company's hiring practices in China.
  • Individual in FIFA investigation and prosecution pending in the US District Court for the Eastern District of New York.
  • Employee of defense contractor in prosecution pending in the US District Court for the District of New Jersey alleging bribery in connection with construction contracts in Iraq.
  • Leading US biotechnology and pharmaceutical manufacturer on establishing a clinical trial in Colombia that is compliant with all anti-corruption requirements.
  • US automotive industry component and parts supplier on investigation issues, which include compliance reviews in China, Brazil, and Mexico.
  • Major pharmaceutical company in a comprehensive global compliance assessment, including reviews of operations in Asia, Latin America, and the EU.
  • Private equity firm in connection with evaluating possible corruption risks of potential portfolio investments and developing a full anti-corruption compliance program.
  • Third-party marketing representatives of major oil and gas company in connection with FCPA compliance audit of activities in South America.
  • Large US multinational corporation in a series of internal investigations of possible FCPA violations in Latin America.
  • Large defense company in an internal investigation of possible FCPA violations in Africa.

Perspectives

Risk & Compliance Management 2017: United States (pdf)
Getting the Deal Through
Managing FCPA and Corruption Risks in Third-Party Relationships
Arnold & Porter Kaye Scholer LLP
Managing Corruption Risks in Life Sciences and Healthcare M&A
Arnold & Porter Kaye Scholer LLP
UK Economic Crime Group—Enforcement Update
Newsletter
Global Anti-Corruption Insights: Winter 2017
Update on Recent Enforcement, Litigation, and Compliance Developments
More

Recognition

Chambers Global
Fraud & Corporate Investigations (Latin America-wide) (2015-2017)
Corporate Crime & Investigations (US) (2016-2017)
Chambers Latin America
Fraud & Corporate Investigations (2015-2016)
The Legal 500 UK
Corporate Crime (including Fraud, Bribery, and Corruption) (2014)
Overview

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