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In a climate of increased regulation and enforcement, domestic and foreign companies and the individuals who lead them rely on Arnold & Porter for global anti-corruption matters. We have deep experience with the U.S. Foreign Corrupt Practices Act (FCPA), UK Bribery Act, and many other anti-bribery laws and regulations, and we bring that experience to the investigations, enforcement actions, and litigation — as well as due diligence, risk assessments, and compliance counseling — we regularly handle for clients all over the world. Our Anti-Corruption team includes high-level former government prosecutors and other seasoned attorneys who provide our clients with practical, real-world advice that balances legal and business objectives and who are prepared to mount a vigorous defense, where appropriate.

  • Full Coverage: With extensive experience around the globe and in a variety of industries — including life sciences, financial services, energy, technology, consumer products, retail, defense, aerospace, and private equity — we provide comprehensive coverage for our clients across all of our disciplines to meet their needs.

  • Customized Compliance: Authorities recognize — and so do we — that organizations may have different compliance needs depending on their size, structure, geographic footprint, industry, regulatory landscape, and other risks associated with their operations. Because our attorneys regularly interact with leading government authorities on compliance matters, we can offer fresh and timely insights into how regulators evaluate compliance programs.

  • Distinguished Government Insiders: Our team features a deep roster of former high-level officials from the DOJ, SEC, UK Serious Fraud Office, and other government agencies that enforce anti-corruption laws.

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Experience Highlights

  • Leading international shipbuilder in a Deferred Prosecution Agreement with the DOJ, coordinated leniency agreements with three government agencies in Brazil, and collateral litigation related to the high-profile "Operation Car Wash" scandal involving Petrobras.
  • Former Embraer executive in a global FCPA investigation by US, Brazilian, and Saudi authorities. At sentencing, after a five-year investigation and prosecution, the US District Court for the Southern District of New York rewarded the individual for his cooperation by ordering only forfeiture and a small fine, with no jail or probation.
  • Publicly traded multinational art auction house in investigation by the DOJ in connection with the Jho Low-1MDB Malaysian corruption and money laundering scandal.
  • UK and Israeli law firm in serving as expert witness relating to FCPA and other US law issues in Vale et al. v. Steinmetz et al., a UK court proceeding.
  • Fortune 200 IT and professional services company on anti-corruption risk assessments, due diligence, and compliance program integration relating to more than a dozen international corporate acquisitions.
  • Global pharmaceutical company in an investigation by the SFO, SEC and DOJ regarding bribery allegations involving China and other jurisdictions.
  • Global pharmaceutical company in internal investigation relating to alleged bribery and bid-rigging in Asia.
  • Publicly traded American retailer in post-Deferred Prosecution Agreement compliance monitoring, risk assessments, training, enhancements, and required reporting to DOJ.
  • Multiple employees of major financial institution in connection with DOJ and SEC "Sons and Daughters" investigation into institution's hiring practices in China.
  • Global telecommunications company in FCPA investigation involving the company's activities in more than 15 countries in Europe, the Middle East, and Central America. Successfully led company's cooperation with the DOJ, the SEC, the SFO and Austria. Obtained formal declinations from DOJ and SEC.
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