Capabilities
White Collar Defense

Anti-Corruption

In this climate of increased regulation and intensified enforcement, clients turn to Arnold & Porter 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. Our team has vast experience in conducting internal investigations in response to potential corruption issues around the world.

We have represented global leaders in diverse industries that span electronics, manufacturing, pharmaceuticals, media, cosmetics, financial services, defense and aerospace, extraction, 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 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

  • Leading telecommunications company in connection with an FCPA investigation and related prosecutions involving the company's activities in more than fifteen countries in Europe, Asia, including China, and the Middle East.
  • Leading telecommunications company in ongoing internal investigation into allegations of bribery, antitrust violations, and fraud arising out of company's sales of radio systems to Ukrainian governmental agencies.
  • Leading pharmaceutical company in internal investigation into whistleblower allegations of alleged commercial bribes paid in connection with construction of major manufacturing facility in Singapore.
  • American coffee company and coffeehouse chain in a comprehensive risk assessment on the strengths and weaknesses of its anti-bribery compliance program after conducting on-site assessment of operations in China, Russia, Brazil, Thailand, Mexico, Peru, UK, and India and at support centers for the Latin America, EMEA, and Asia-Pacific markets.
  • South Korean retail conglomerate in a comprehensive risk assessment of anti-corruption, conflicts of interest, and anti-trust/fair trade risks for the company in light of ongoing government investigations.
  • Major ship manufacturer in ongoing high-profile "Operation Car Wash" Petrobras corruption investigation.
  • Individual in high-profile ongoing prosecution regarding allegations of bribery in connection with US government contacts to rebuild Iraq following the US-led invasion.
  • Publicly trade multinational art auction house in ongoing investigation brought by the DOJ in connection with the Jho Low-1MDB Malaysian corruption and money laundering scandal.
  • Former Embraer manager in connection with an FCPA investigation brought by the DOJ.
  • Former general counsel of Amsterdam-based telecommunications company in major FCPA investigation.
  • Multinational equipment manufacturer headquartered in Japan in ongoing anti-corruption investigation involving operations in India.
  • New York area community hospital in high-profile health care fraud and political corruption investigation conducted by US Attorney's Office for the Eastern District of New York.
  • Multinational company in the extractive industry sector in internal investigation regarding allegations of corruption responding to whistle-blower communication.
  • Global investment bank in multinational investigation concerning allegations arising under the FCPA and other anti-corruption laws.
  • Chilean victim of massive corruption scheme by former head of Chile’s Securities & Exchange Commission to steal as much as $70 million.
  • Major NYSE company equipment supplier in anti-corruption compliance review in 5 major markets in South America and Mexico.
  • Multinational company in internal investigation of transaction in Indonesia.
  • Multi-national pharmaceutical company in connection with the anti-corruption and FCPA aspects of its $100 million acquisition of a Mexican drug company.
  • Brazilian subsidiary of a FORTUNE 100 US-headquartered company on their FCPA compliance, and we provide related ongoing counseling and training on anti-corruption 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

Supreme Court Overturns Federal Prohibition on State Authorization of Sports Wagering Under the Professional and Amateur Sports Protection Act
Advisory
Emerging Legal Issues in Multi-Jurisdictional Enforcement Actions
Panelist, The George Washington University Law School's Emerging Issues in Foreign Corrupt Practices Act (FCPA) Enforcement, Washington, DC
New Law on the Tax-Deductibility of False Claims Act and Other Government Settlements
Advisory
Global Anti-Corruption Insights: Winter 2018
Update on Recent Enforcement, Litigation, and Compliance Developments
DOJ Announces New FCPA Corporate Enforcement Policy
Advisory
More

Recognition

Chambers Latin America
Fraud & Corporate Investigations (2015-2018)
Chambers Global
Fraud & Corporate Investigations (Latin America-wide) (2015-2017)
Corporate Crime & Investigations (US) (2016-2017)
The Legal 500 UK
Corporate Crime (including Fraud, Bribery, and Corruption) (2014)
Overview

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