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Foreign Corrupt Practices Act & Global Anti-Corruption

Contacts

William M. Sullivan, Jr.
Partner, Washington, DC
T: +1.202.663.8027
Stephan E. Becker
Partner, Washington, DC
T: +1.202.663.8277
Nancy A. Fischer
Partner, Washington, DC
T: +1.202.663.8965
Christopher R. Wall
Partner, Washington, DC
T: +1.202.663.9250
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Pillsbury is a leader in advising on the Foreign Corrupt Practices Act (FCPA) and global anti-corruption matters, providing guidance on general compliance and specific transactions and handling investigations and representation before government agencies.

Facing a marked increase in U.S. Foreign Corrupt Practices Act enforcement activity, businesses engaged in international trade rely on Pillsbury for the full range of FCPA-related services, from general compliance and advice on specific transactions to investigations and representation before government agencies when potential issues are uncovered.

To best serve our clients, Pillsbury has created a multidisciplinary team dedicated to providing exceptional guidance on complex legal and regulatory issues that arise when doing business abroad. Our lawyers closely monitor U.S. court decisions, the terms of DOJ and SEC settlements, and policy statements of enforcement officials and regulators to provide up-to-the-minute advice. We offer insight to executives and inside company counsel on interpretation issues and guide clients through all aspects of FCPA compliance and enforcement. Our team provides full-service solutions for companies, helping them establish effective FCPA compliance programs and respond to potential violations when they arise. Further, we handle internal investigations and regulatory probes and assert and defend our clients’ position in court and before regulatory bodies.

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Our services include:

  • Advising on sensitive payments, conducting investigations and advising committees of companies’ boards of directors
  • Representing companies and individuals under investigation or charged with violations in both civil and criminal proceedings
  • Assisting companies with preparing and implementing internal control programs for FCPA compliance
  • Conducting due diligence reviews of potential acquisition targets, business partners and agents
  • Analyzing and structuring transactions to avoid potential FCPA liability, and drafting contract clauses for agreements with foreign representatives
  • Training U.S. government contractors on FCPA compliance related to foreign projects
  • Advising on permitted sales and marketing activities involving government officials
  • Coordinating with foreign local counsel to determine whether specific activities are lawful in the foreign jurisdiction

Representative Experience

  • Represented a major U.S. aerospace company in connection with internal investigations of possible FCPA violations in China, Greece, Spain, Argentina, Saudi Arabia and Indonesia.
  • Represented a petroleum and natural gas engineering company in a high-profile parallel SEC/DOJ FCPA investigation in which we persuaded both agencies to decline criminal and civil enforcement actions.
  • Represented a multinational company with operations in China in an internal investigation into allegations of payments to government officials. The payments were allegedly disguised as sales commissions to government officials outside of China.

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  • Aerospace & Defense
    • Represented a publicly traded U.S. manufacturer of military equipment in connection with a criminal investigation in which the government had for the first time used informants, wiretaps and other “sting” enforcement technologies.
    • Advised major defense contractor on FCPA compliance in connection with potential sales to Middle East governments through required local country partners.
    • Conducted an FCPA internal investigation for U.S. defense manufacturer in connection with sales and third-party agent activities in Mexico.
    • Represented a major U.S. aerospace company in connection with internal investigations of possible FCPA violations in China, Greece, Spain, Argentina, Saudi Arabia and Indonesia.
    • Conducted anti-corruption training and prepared compliance materials for a defense contractor active in the Middle East.
    • Advised a major U.S. defense contractor on FCPA risks in the use of foreign agents and due diligence guidance to mitigate the risk associated with foreign agents.
    • Assisted a foreign-based aerospace company in preparing its anti-bribery policy, and advised it on the scope of the FCPA.
  • Consumer & Retailer
    • Represented a former senior executive of a Fortune 50 company in connection with an internal investigation of potential FCPA issues; obtained declination from government agencies in relation to subsequent SEC administrative and DOJ criminal inquiries.
    • Assisted a Fortune 500 company with FCPA compliance audit, updating internal policies and procedures, drafting related forms and documents, and preparing an internal anti-corruption training program and presenting it to all of its managers and buyers.
    • Advised international media company on FCPA best practices when hiring local agents in high-risk jurisdictions.
    • Advised a Norwegian company on drafting and implementing a global anti-corruption compliance program, including the FCPA, UK Bribery Act and Norwegian anti-corruption laws.
    • Represented a major U.S. retailer in connection with an internal investigation into possible FCPA and China anti-bribery violations including due diligence and interviews with key employees and vendors in China.
  • Energy
    • Represented a foreign multinational energy and transportation company regarding a comprehensive DOJ international criminal investigation.
    • Represented the Audit Committee of a U.S.-listed, Chinese-based petrochemical company in an internal investigation involving allegations of accounting improprieties and potential violations of the FCPA.
    • Assisted an international energy company in an internal investigation into whether the entertainment of employees from oil companies owned by Venezuelan and Brazilian governments was in violation of the FCPA.
    • Represented a petroleum and natural gas engineering company in a high-profile parallel SEC/DOJ FCPA investigation into allegations of improper payments to government officials in Nigeria in connection with the construction and subsequent expansion of LNG projects, and successfully persuaded both agencies to decline criminal and civil enforcement actions.
    • Advised a company on adopting an anti-corruption compliance policy and supplier due diligence questionnaires.
    • Organized a crisis management effort in response to report of potential bribery, including travel locations in Africa to instruct local counsel, local business leads, and potential new agents and personnel.
  • Engineering & Construction
    • Represented an international engineering company in an internal investigation into allegations of bribery of Saudi Arabian officials in connection with the sale of wastewater treatment equipment.
    • Represented a petroleum and natural gas engineering company in a high-profile parallel SEC/DOJ FCPA investigation in which we persuaded both agencies to decline criminal and civil enforcement actions.
    • Conducted extensive internal investigation on FCPA and Brazilian anti-corruption law compliance for Asian company investors in the Brazilian ship building industry.
    • Assisted a multinational engineering services and consulting company with parallel investigations by DOJ and the World Bank involving allegations former employees violated the FCPA.
    • Represented a publicly traded industrial materials company in an internal investigation involving allegations of potential violations of the FCPA in Eastern Europe and the former Soviet Union.
    • Assisted a global manufacturer with conducting a comprehensive FCPA review of its policies, practices and procedures.
    • Prepared FCPA and China anti-corruption compliance policies and drafted anti-corruption clauses for distribution and local agent agreements for a U.S. manufacturing company expanding its business in China.
    • Provided training sessions to staff of a global nuclear services construction company and assisted the company with preparation of a standardized anti-corruption due diligence checklist.
  • Financial Services
    • Helped a European banking client to prepare AML forms and procedures for KYC and beneficial ownership in light of U.S. and EU regulations and evolving best practices.
    • Conducted assessment of banking industry perception of AML compliance practices for EU member country and coordinating with U.S. correspondent bank fraud/compliance departments.
    • Conducted due diligence on FCPA compliance in connection with private equity acquisitions.
    • Assisted an international fund in reviewing activities and policies and preparing FCPA/UK Bribery Act Compliance Statements for investors.
    • Advised investors on anti-corruption, sanctions and other compliance considerations in relation to an investment in a Sierra Leone transportation company.
    • Counseled a private equity firm focused in the nuclear sector with FCPA and export control compliance related to joint ventures, investments and agents in high-risk Middle Eastern countries, including the challenges associated with royal family member partners and agents.
    • Represented a private equity firm in FCPA due diligence of potential acquisition of a large IT defense contractor.
  • Manufacturing Use & Shipping
    • Conducted group training on anti-corruption covering the FCPA and UK, Japan and World Bank regimes for client in Japan.
  • Technology
    • Advised an Israeli technology company on FCPA compliance related to hiring government employees to assist with research and development.
    • Assisted a technology company with operations in Latin America in establishing a compliance program, training materials, and agreements with in-country sales representatives.
    • Conducted an internal investigation for a publicly traded U.S. electronics company into allegations of prohibited sales activities in China.
    • Represented a multinational company with operations in China in an internal investigation into allegations of payments to government officials. The payments were allegedly disguised as sales commissions to government officials outside of China.
    • Counseled a provider of integrated computer network performance management products on anti-corruption due diligence and assessment of policies and procedures in the acquisition of a UK-based voice and video management company.
    • Advised a technology company on a proposal to host foreign government officials to demonstrate their products. Reviewed and analyzed FCPA issues in connection with potential acquisition of a U.S.-based medical optics company by a publicly traded Japanese corporation.
    • Advised a consultant management company on FCPA compliance of potential target companies.
  • Retail
    • Advised a client on the preparation of expanded anti-corruption and ethics procedures and policy statement for U.S. and Mexico operations.
    • Prepared and conducted anti-corruption training covering U.S. and Mexico law for a client.
    • Reviewed and analyzed FCPA issues in connection with anti-corruption due diligence for a Chinese e-commerce provider.
  • Satellite
    • Advised a satellite company on AML regulatory and criminal rules in relation to transactions in Africa.
  • Telecommunications
    • Assisted with FCPA due diligence in connection with investment in a telecommunications company with operations in various countries in Latin America.
    • Conducted FCPA, UK Bribery Act and Chinese anti-corruption law training for many clients in the telecommunications, manufacturing, technology and life sciences sectors.
    • Represented a former executive of a Hungarian telecommunications company in a parallel SEC/DOJ investigation involving allegations of bribery of government officials in Macedonia and Montenegro.
    • Prepared FCPA compliance guide for use by a communications company in educating its employees.
    • Advised a satellite services company on the structuring of its relations with radio spectrum coordination and oversight consultants in Russia to avoid potential FCPA concerns.
  • Travel Use & Transportation
    • Represented a former senior executive of an international provider of freight forwarding and logistics services in a DOJ investigation into whether that company’s freight-forwarding and customs clearance practices in Nigeria and Saudi Arabia violated the FCPA.
    • Assisted a U.S.-based airline with conducting a comprehensive FCPA review of its policies, practices and procedures, and provided FCPA training.

Practice Area Highlights

  • Pillsbury is recognized as among the most feared law firms for litigation by BTI Consulting Group.
  • Pillsbury’s International Trade practice is nationally ranked by Chambers USA and internationally recognized by Chambers Global for our Export Controls & Economic Sanctions, CFIUS, and Trade Remedies & Trade Policy work.
  • Pillsbury received U.S. News/Best Lawyers recognition for International Trade & Finance.

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  • Recognized in 2024 by The Legal 500 U.S. for the breadth of our International Trade capabilities across three categories: CFIUS; Customs, Export Controls and Economic Sanctions; and Trade Remedies and Trade Policy.

Resources

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