Andrew P. Thornton-Dibb

Andrew P. Thornton-Dibb Associate

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Andrew is a member of the firm’s nationally ranked Government Investigations and White Collar Litigation practice, and frequently assists companies and their leaders navigate complex issues with criminal, regulatory, legal, reputational, and political impacts.

A dual-qualified attorney and solicitor, Andrew joined our D.C. office from London, bringing with him experience in cross-border and domestic matters, including conducting sensitive internal investigations, responding to grand jury and government investigations into criminal and regulatory issues, responding to and preparing for parliamentary inquiries and hearings, and negotiating and concluding resolutions with enforcement authorities.

His work has focused on matters concerning corruptions laws, including the UK Bribery Act and the FCPA, securities fraud and market manipulation, complex fraud, financial services regulation, and sanctions and money laundering issues, that have involved a number of authorities, including the DOJ, SEC, OCC, the FEC, FINRA, the UK’s Serious Fraud Office, the FCA, Trading Standards, the Health and Safety Executive, the City of London Police Economic Crime Directorate, and the German Public Prosecutor General.

Andrew also has an active pro bono practice focusing on anti-human trafficking matters.


  • Successfully secured the second Deferred Prosecution Agreement (DPA) to be approved in the UK.
  • Counsel to a UK technology company and its US parent concerning a Bribery Act/FCPA investigation and subsequent self-report to the UK’s Serious Fraud Office concerning conduct in China, Korea, and India.
  • Counsel of a major financial institution in multi-year enforcement actions by the OCC, SEC, and DOJ that resulted in a DPA.
  • Counsel to Fortune 100 corporation in multi-year grand jury investigations into matters arising from the distribution and sale of opioids.
  • Counsel to a major automotive company in investigations by German authorities into alleged international bribery that resulted in a declination.
  • Counsel to a South Asian headquartered company in government investigation and related internal investigation into suspected UK Bribery Act offenses.
  • Counsel to a UK Company in a government investigation and related internal investigation into potential breaches of Iranian sanctions and associated export controls.
  • Counsel to an individual in a UK/US cross-border Libor manipulation investigation.
  • Conducted an internal investigation concerning complex fraud relating to misappropriating ~$500m of assets backing financial instruments.
  • Counsel to an international Fortune 500 in a corporate manslaughter investigation conducted by health and safety enforcement authorities.
  • Representation of international certification and auditing company in SEC investigation.
  • Represented financial institutions in responding to FINRA inquiries.
  • Representation of US companies concerning alleged improper corporate reimbursements of federal and state political contributions.
  • Assisting clients in the assessment and defense of claims under Titles III of the Helms-Burton Act.
  • Advising multiple clients on preparing and updating anti-bribery and other compliance policies and procedures.