International Investigations & Enforcement
Companies and individuals facing complex, multi-jurisdictional inquiries have consistently relied on our premier International Investigations and Enforcement attorneys to guide them through sensitive investigations; identify and mitigate risk; leverage our team’s extensive government experience to resolve matters favorably; and, when necessary, aggressively litigate civil and criminal enforcement actions. As cross border investigations and enforcement matters have continued to expand in scope, size and topic over the past 15 years, our lawyers have been at the forefront of many of the most significant resolutions, providing sophisticated advocacy for clients facing serious criminal, civil, and regulatory investigations around the world.
The International Investigations and Enforcement Team includes members of our Government Investigations and White Collar Litigation Department, which has been recognized twice as a Law360 Group of the Year. Our seasoned defense attorneys have significant experience working for the government agencies that initiate investigations against our clients. The group includes a former Deputy Attorney General and acting Attorney General of the United States, former Associate Deputy Attorney General, former U.S. attorneys, and more than a dozen federal prosecutors and other former enforcement officials, as well as lawyers who have been recognized by Chambers USA, Best Lawyers in America, Legal Elite and Super Lawyers as among the top legal service providers in the nation.
Our team – with noted practitioners in a number of our U.S. offices as well as in our London office – consistently manages complex matters that span multiple jurisdictions and touch an array of substantive areas such as the FCPA and other anti-corruption issues, antitrust, anti-money laundering, bank fraud, and sanctions issues, among others. We are accustomed to the unique aspects of an international practice, including spearheading extensive foreign language reviews, managing complex data privacy issues, leveraging our in-house e-discovery expertise for multi-jurisdictional document requests, and working seamlessly with counsel in other jurisdictions. We handle matters across the globe, with extensive experience throughout Latin America, Europe, the Middle East, and China.
How We Help
We represent major domestic and foreign companies, financial institutions, international organizations, boards of directors, and special committees, as well as senior executives and other individuals, in high-stakes investigations and enforcement actions, often involving multiple jurisdictions or government agencies. Our attorneys have represented clients in some of the most significant cross-border matters of the past decade, helping to coordinate clients’ global defense and investigation strategies and achieve favorable civil and criminal resolutions.
In addition to defending our clients before U.S. and foreign enforcement agencies, we also regularly conduct internal investigations, audits, and risk assessments, and provide compliance counseling across a number of substantive areas, such as anti-corruption and anti-bribery; anti-money laundering; sanctions and export controls; and antitrust issues. Our clients trust us to:
- Defend them in complex international investigations involving multiple criminal or civil enforcement agencies, including representing them in high-stakes criminal trials;
- Develop and provide general and operation-, function-, or region-specific compliance training;
- Efficiently handle criminal, civil, and regulatory actions arising from the same underlying events;
- Conduct pre-merger and post-merger acquisition due diligence, and assist with follow-on business and compliance integration efforts;
- Assess existing compliance programs, or develop new compliance programs tailored to their particular risks;
- Represent them in grand jury proceedings, government interviews, and other criminal processes;
- Conduct internal investigations;
- Conduct third-party due diligence and help develop and deploy third-party due diligence protocols and programs; and
- Perform audits and assessments to help them understand and mitigate the risks they face;
- Develop hotlines or other issue reporting and escalation procedures, and assist in the review and resolution of reported issues.
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- Representing the largest construction conglomerate in South America, in what the U.S. Justice Department has described as “the largest-ever global foreign bribery resolution,” including counseling the client in its negotiations with U.S. investigators and coordinating the global strategy in reaching a resolution between U.S., Brazilian and Swiss investigators and the client and its affiliate.
- Representing two major Brazil-based companies in enforcement actions by the DOJ and SEC stemming from the largest bribery scheme in Brazilian history, and achieving a resolution with all U.S. regulators which resulted in removing U.S. criminal and civil exposure for the conduct for a fraction of the fine levied against the entities in Brazil.
- Counseling a confederation of the ten South American national soccer teams, in connection with U.S. criminal investigations and prosecutions into allegations of bribery and corruption in the international soccer world.
- Defending a successful American entrepreneur who founded and served as co-CEO of a Colombian oil services company, in the highest profile FCPA trial of recent years. In what was described by the national media as a “striking victory for the defense,” the U.S. Department of Justice agreed in the middle of trial to drop all of the most serious charges against the client, including those relating to substantive bribery, kickbacks, defrauding investors and money laundering and wire fraud, permitting the client to receive no jail time and avoid the 20 years in prison prosecutors had sought.
- Conducting an extensive anti-corruption internal investigation for a major international oil company in connection with FCPA investigations by the SEC and DOJ, and representing that company in its resolutions with both government agencies.
- Representing a global financial institution before the SEC, DOJ, and banking regulators in an anti-corruption, AML, and securities investigation arising from conduct in Brazil.
- Representing a global financial institution before the DOJ and U.S. and foreign banking regulators based on conduct in Latin America and Switzerland.
- Conducting an internal investigation for a publicly-traded specialty chemicals company to address whistleblower allegations of corrupt payments being made to government officials in China, including a risk analysis and review of the company’s entire global ABAC compliance program.
- Providing regular FCPA counseling to an international telecommunication and wireless company, including monitoring and updating related compliance policies.
- Representing a UK technology company and its U.S. parent in relation to an investigation and subsequent self-report to the Serious Fraud Office in relation to improper payments made through agents to secure contracts in China, Korea and India and successfully secured the second Deferred Prosecution Agreement to be approved in the UK.
- Defending a company officer facing prosecution in the UK and advising the linked company with clients in U.S. and Europe, in relation to a seven-year cross-border UK Bribery Act prosecution and interconnected money laundering.
- Regularly representing foreign-based nationals—including individuals in the UK, Israel, and Brazil—in matters before the SEC and DOJ.
- Conducting periodic FCPA program reviews and audits for a Fortune 500 company, covering its businesses in North America, Europe and Asia, including site reviews of operations throughout Latin America, and Eastern and Western Europe.
- Conducting regular anti-corruption and antitrust audits for a publicly traded company’s operations throughout Latin America, including foreign language document review and employee interviews.
- Assisting a global Fortune 500 consumer products company with development of a comprehensive anti-corruption compliance program in connection with its expansion into non-U.S. business activities, most notably in Latin America and China.
- Conducting a series of FCPA reviews and investigations for a Fortune 10 company regarding business operations in countries throughout the world, including site reviews in Central and South America (Mexico, Argentina and Brazil).
- Conducting an internal investigation regarding violations of the UK Bribery Act by an agent in China for a UK company in the steel industry.
- Conducting pre-merger FCPA due diligence reviews throughout the world, including Europe, South America and Asia, as part of a multibillion-dollar acquisition by a Fortune 500 pharmaceutical and medical device company.
- Providing regular FCPA-related M&A due diligence reviews for multiple clients, including a Fortune 500 company, including business units subject to the terms of DOJ and SEC settlement agreements related to violations of the United Nations’ Iraq Oil-for-Food program.
- Assisting a global Fortune 500 mixed industrial client with the management of a comprehensive third-party due diligence program covering hundreds of third parties across multiple lines of business operating in dozens of countries on six continents.