Stephen Martin focuses his practice on global compliance matters, risk assessment and management and advising companies in connection with corporate internal and governmental investigations. He counsels clients on developing, implementing and enhancing corporate compliance and ethics programs to address a broad range of potential risks, including anti-corruption/anti-bribery (FCPA and UK Bribery Act), antitrust, privacy, cyber-security, data protection and information management, Dodd-Frank Act, environmental and corporate social responsibility.

Mr. Martin has significant government, corporate and private practice experience. He began his career as an Assistant Attorney General for the state of Missouri, and subsequently served as an Assistant US Attorney for the District of Columbia. He later worked in-house in various roles as legal counsel and as lead compliance officer for several major corporations during which time he worked on significant governmental and internal investigations, litigation and compliance matters, including designing and implementing broad-based compliance programs. Mr. Martin also was integral in the creation and development of a corporate compliance consulting practice at an Am Law 100 law firm.

Mr. Martin works internationally with clients in handling both proactive and reactive compliance related matters. He has personally handled internal investigations; enterprise, global and in-country risk assessments; and compliance program/risk management enhancement and remediation work for clients in a number of different countries, including Russia/CIS region, Brazil, United Kingdom, Thailand, Indonesia, Korea, Malaysia, Netherlands, Spain, Italy, Philippines, Mexico, Madagascar, South Africa, Vietnam and Zimbabwe. Mr. Martin works with clients on a global basis across a wide array of industries, including retail, food and beverage, oil and gas, logistics/shipping, pharma/biotech, medical device, insurance, construction, manufacturing, telecom and private equity.

Experience

  • Retained by a technology company to conduct an internal investigation of potential FCPA violations in Russia, Kazakhstan and the CIS region and advise on worldwide transaction testing. Conducted a global compliance risk assessment and advised on enhancement of the company’s compliance program. Represented client in self-disclosure presentations before the DOJ and SEC that resulted in a declination by the government.
  • For a leading manufacturer of building materials contemplating a US$2 billion joint venture with an Australian company, led an extensive in-country enhanced due diligence review and investigation of potential FCPA compliance issues and conducted a regional compliance risk assessment in China, India, Indonesia, Korea, Malaysia, Philippines, Singapore, Thailand and UAE that was the precursor to successfully closing the transaction. Advised on creating a post-closing integration compliance plan. Conducted FCPA risk assessments for the Mexico and India operations of the building materials manufacturer.
  • Evaluated the compliance program for a global logistics and freight forwarding company offering air/ocean freight consolidation and forwarding services, customs clearance, and cargo insurance capabilities across many high-risk emerging markets. Advised the company on best practices for financial, operational and regulatory/legal compliance given the FCPA, trade sanctions and customs risks and regulatory environment in which it operates. Recommended a compliance structure and program recommendations targeted to address company- and industry-specific issues identified in the assessment.
  • Retained by a manufacturing company to conduct an investigation and compliance review in Mexico. Conducted additional compliance reviews in Russia/CIS. Hired to investigate potential FCPA/accounting fraud issues in China.
  • Served as global compliance counsel for the leading water infrastructure company during a World Bank monitorship, and assisted the company in enhancing its compliance program following a compliance/risk assessment and compliance program review. Represented the company in communications with the World Bank and the Corporate Monitor resulting in the company being successfully released a year early from the World Bank VDP Monitorship. Worked directly with the CEO and Board of Directors on the monitor related activities.

  • Advised a medical devices client on remediating audit findings related to its third-party distributor program. Assisted the client in preparing third-party due-diligence program materials and in preparing related policies, procedures and materials.
  • Conducted a comprehensive compliance review and risk profile mapping project across multiple risk areas for the US subsidiary of a leading global energy client and made recommendations for an effective risk-based US compliance program. Presented findings to the US CEO, legal/compliance team and international HQ executives in legal, compliance and audit.
  • For a leading food company, conducted an enterprise-level FCPA risk assessment (including reviews/training in China, Korea and Thailand) to make recommendations for enhancing the company's global compliance program. Assisted company with commercial agreement and trade compliance issues. Advised on significant M&A transaction in China.
  • Evaluated and advised multinational food and beverage company on the anti-corruption compliance program for its Brazil operations following an in-country assessment of existing corruption and commercial bribery risks and risk management efforts.
  • Conducted enterprise-wide anti-bribery risk assessment for global food and beverage retailer and advised on enhancements to its compliance program. Work included conducting on-site assessment of operations in China, Russia, Brazil, Thailand, India and Mexico as well as operational centers for the Latin America and Asia-Pacific markets. Provided company with new investigation policy and regulatory subpoena response plan. Developed compliance toolkit for distribution to third-party vendors and licensee partners.
  • Evaluated and advised a global chemical and materials producer on its global compliance program, including policies and procedures addressing antitrust and anti-corruption issues in high-risk emerging markets. Presented findings to the Board of Directors.
  • For a leading environmental NGO, conducted a comprehensive compliance and risk management review, including in-country risk assessment work in Madagascar, Indonesia, Peru and Brazil. Presented findings to the Board of Directors and assisted management in developing a plan for implementation of the recommendations.
  • For a retail company, assisted company with supply chain compliance risk assessment and program development/enhancement, including corporate social responsibility advice.
  • Conducted a comprehensive compliance review and risk profile mapping project for a retail beverage company across multiple risk areas (antitrust, FCPA/anti-corruption, food and product safety, trade, data protection/privacy, corporate governance, environmental, global mobility and labor/employment, financial controls and tax). Made recommendations for creating a US compliance program and presented findings to the CEO and executive management team. Assisted with implementation of assessment findings.
  • Conducted an enterprise-level FCPA risk assessment for domestic and international operations of a fast-growing pharmaceuticals company to make recommendations for creating a global FCPA/anti-corruption compliance program.
  • Retained as Global Compliance Counsel to assist telecommunications company in developing and enhancing its compliance program worldwide. Responsible for addressing compliance issues across a number of areas, including anti-bribery, data protection, M&A due diligence and third-party management. Worked with company's Investigation Counsel to address the DOJ/SEC investigation and compliance program enhancements in preparation for a monitor.
  • Retained by a transportation company under a Deferred Prosecution Agreement to conduct a risk assessment/compliance program review.
  • Retained by an energy company to conduct an enterprise-wide risk assessment and make recommendations to Board regarding compliance program enhancements.
  • Retained by a financial services company to conduct a compliance program assessment and make appropriate recommendations to the senior management on structure and organization and create a compliance program enhancement plan to meet government expectations.

Perspectives

Deskbook on Internal Investigations, Corporate Compliance and White Collar Issues (2nd Edition)
PLI Practising Law Institute
Effective Auditing and Monitoring and Best Practice Tips for Responding to Internal Misconduct and Conducting Internal Investigations
Arnold & Porter LLP
A Practical Framework to Ensure Compliance Program Effectiveness
Arnold & Porter LLP
How Effective Is Your Compliance Program?
Arnold & Porter LLP
DOJ Launches FCPA Enforcement Pilot Program to Encourage Voluntary Disclosure
Arnold & Porter Advisory

Recognition

The Legal 500 US
Corporate Investigations and White-Collar Criminal Defense (2017)

Credentials

Education
  • MBA, University of Denver, 2006
  • LLM, Georgetown University Law Center, 1998, with distinction
  • JD, Creighton University, 1994
  • BA, Public Affairs and Political Science, University of Denver, 1991
Admissions
  • Colorado
  • District of Columbia
  • Missouri
Overview

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