Experience
Working as key team member for the independent compliance monitor as appointed by the DOJ and two separate multilateral development banks for a large South American company in the wake of a multi-jurisdictional resolution worth billions of USD.
Conducted an internal investigation into potential FCPA violations at a foreign subsidiary of a Fortune 500 multinational corporation. Conducted more than 60 interviews of employees, reviewed business lines and relationships with key customers and distribution channels, and conducted forensic analysis of accounting records and internal controls. Investigation included a review of business units in more than 15 countries to assess FCPA risks.
Conduct an internal investigation into allegations of improper payments made to a government official in a Latin American country, which included assisting with recommendations to enhance and improve the Company’s compliance program and implementation of those remedial measures.
Representation in an SEC FCPA investigation involving conduct in Latin America related to our client’s engaging in a business relationship with a company that was subsequently involved in a government corruption scandal.
Represented the audit committee of an international supplier of agricultural products in its internal investigation resulting from a whistleblower complaint alleging violations of the FCPA in the Middle East. This matter was one of the first cases to be reported to the SEC under its whistleblower rules enacted in 2011. After we completed the investigation and reported the result to the SEC, it declined to conduct an investigation of its own and closed the file.
Represented a Fortune 500 company with anti-corruption due diligence in connection with the acquisition of a foreign telecom company with substantial operations in Africa, Latin America, Southeast Asia and the Middle East.
Represented a senior executive of a global retailer in connection with an investigation by the DOJ, SEC and other agencies into possible violations of the FCPA in Mexico, Brazil and other countries.
Representation in connection with inquiries from banking regulators regarding the Bank’s relationships with customers and entities involved in well-known corruption and money laundering schemes as well as the Bank’s own BSA/AML controls, which implicates bank secrecy laws and the privacy and data security laws of various jurisdictions.
Conducted an independent assessment of the Company’s compliance program, including reviewing the bank’s governance, internal controls, audit, and filtering systems, to ensure compliance with U.S. sanctions laws pursuant to a Consent Order entered into with the Board of Governors of the Federal Reserve System.
Conducted a multi-year internal investigation into anti-money laundering controls and potential violations of U.S. sanctions laws at the New York branch of the Bank, which culminated in a deferred prosecution agreement to settle allegations made by federal and state regulators. The representation also involved securing a motion to dismiss in a related civil action where Plaintiffs sought over US $1 billion directly from the Bank related to allegations of fraudulent conveyance.