Through decades of experience, Steptoe has earned a national reputation as a go-to firm for boards, audit committees, special committees, companies, and other institutions conducting sensitive internal investigations and compliance reviews.
Our team includes former officials from a wide range of law enforcement and regulatory agencies, including the Department of Justice (DOJ), the Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), Federal Bureau of Investigation (FBI), the Department of Homeland Security (DHS), the Department of the Treasury, the Internal Revenue Service (IRS), the Federal Trade Commission (FTC), the Federal Energy Regulatory Commission (FERC), the Department of Treasury’s Office of Foreign Assets Control (OFAC), the Department of State’s Directorate of Defense Trade Controls (DDTC), the Department of Commerce’s Bureau of Industry and Security (BIS), and the New York County District Attorney's Office.
We conduct independent investigations for boards and board committees, and internal investigations for public and privately-held companies, universities, and government institutions. Steptoe lawyers provide crisis management advice and we work with our clients to help them avoid or limit exposure before federal and state government agencies in related litigation, and in the press. In addition, in connection with an investigation, our lawyers frequently design and implement remedial and preventive compliance measures, enhance compliance programs and controls, and provide business and governance counseling and guidance.
We have offices around the world that extend our reach for global investigations and allow us to manage data privacy issues when conducting investigations that require us to collect and review documents overseas and interview witnesses in foreign countries.
Our judgment and deep law enforcement and government experience give us the ability to scope investigations properly and economically for our clients. At Steptoe, we don't do "runaway" investigations, and we are sensitive to the disruptions and collateral consequences that such investigations may cause. Our team excels in conducting complex, multijurisdictional investigations efficiently and cost-effectively.
We are recognized by leading legal directories and publications – including Chambers USA, Chambers Global, The Legal 500, and Law360 – for our preeminence in investigations and corporate criminal defense.
Noteworthy
- Global Investigations Review (GIR) 100, Top 30 Firms for Investigations Worldwide (2015-2023)
- Chambers Asia-Pacific, Corporate Investigations/Anti-Corruption (International Firms), Greater China Region (2022-2023)
- Chambers Greater China, Corporate Investigations/Anti-Corruption (2024)
- Chambers Global, Corporate Investigations: Anti-Corruption, Global (2015-2018, 2022)
- Chambers Global, Corporate Investigations/Anti-Corruption, (International Firms), China (2021-2023)
- Chambers Global, Corporate Crime & Investigations, US (2017-2023)
- Chambers Global, Investigations & Enforcement (International & Cross-Border), US (2020-2023)
- Chambers Global, FCPA, US (2017-2023)
- Chambers USA, FCPA, Nationwide (2014-2022)
- Chambers USA, Corporate Crime & Investigations, Nationwide (2015-2022)
- Legal 500 US, Corporate Investigations and White-Collar Criminal Defense: Advice to Corporates and Advice to Individuals (2020-2022)
- China Law & Practice,Shortlisted, International Firm of the Year: Regulatory & Compliance (2018, 2021-2022)
- China Business Law Journal, China Business Law Award: Corporate Compliance (2019-2022)
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Representative Matters
- Conducted an independent review of a global bank’s compliance with SEC rules relating to employees’ use of certain electronic communications platforms.
- Conducted an independent investigation on behalf of the City of Baltimore into the largest corruption scandal in the history of the Baltimore Police Department (gttfinvestigation.org).
- Conducted an independent investigation for the Special Committee of the board of directors of a public fintech company relating to allegations of fraud in the company’s operations in Africa.
- Conducted an investigation on behalf of the Special Litigation Committee of the board of directors of a public biopharmaceutical company involving allegations of financial misstatements, channel stuffing, violations of the Anti-Kickback Statute, retaliation, and other healthcare related issues.
- Conducted internal investigations into whistleblower complaints alleging bribery and other misconduct at a global automobile manufacturer.
- Conducted an internal investigation for a global motorcycle company into allegations of misconduct in connection with sales and revenue reporting.
- Conducted an independent investigation on behalf of a Special Committee of the Board of Directors of Pilot Flying J, the largest travel center and diesel fuel provider in the United States, in connection with allegations that the company defrauded some of its trucking company customers.
- Conducted independent AML/Bank Secrecy Act/sanctions compliance reviews for two of the world’s largest cryptocurrency companies.
- Representation of a crypto mining company and CEO in responding to a FINRA inquiry and conducting an internal investigation related to compliance issues.
- Conducted several workplace culture and misconduct investigations for a large nuclear utility headquartered in the US Southeast – ranging from department-wide assessments to investigations of allegations against single employees and executives.
- Conducted an investigation on behalf of a Japanese construction company and its Latin American subsidiary in connection with allegations by the World Bank of collusion and fraud.
- Conducted an internal investigation on behalf of a multinational private security contractor in connection with allegations of potential improper payments to government officials in Afghanistan.
- Conducted an internal investigation on behalf of a multinational private security contractor in connection with allegations of potential export control violations arising from the export of defense articles from China.
- Conducted a multi-jurisdictional internal investigation into alleged FCPA violations in the foreign operations of a publicly-traded offshore drilling contractor and conducted a review of the company’s compliance program. Based on the thoroughness of the Steptoe investigation, both the DOJ and the SEC terminated their investigations without any enforcement action.
- Conducted an investigation on behalf of a Japanese laboratory services company and its US subsidiary in connection with potential violations of the Anti-Kickback Statute and False Claims Act.
- Conducted an internal investigation on behalf of a Japanese construction machinery repair company and its US subsidiary in connection with allegations of misappropriation of trade secrets and unauthorized access to third-party computers.
- Conducted an internal investigation on behalf of a Japanese automotive textile manufacturer and its US subsidiary in connection with allegations of accounting irregularities.
- Conducted an internal investigation for a government contractor relating to alleged gratuities provided to government officials. Steptoe also conducted a review of, and developed enhancements to, the company’s compliance policies, procedures and employee training programs.
- Conducted an internal investigation on behalf of the operator of a major airport into the operations of the airport's transit system.
- Conducted an internal investigation for a leading oil field services company, relating to possible FCPA violations arising from alleged payments to government officials in multiple countries in sub-Saharan Africa and Southeast and Central Asia.
- Represented a renewable energy investment company’s audit committee in an investigation into certain accounting-related issues raised in a short-seller report.
News & Publications
Press Releases
Meredith Rathbone Elected to Lex Mundi Board of Directors and Executive Committee
May 16, 2024
Media Mentions
May 6, 2024
Client Alerts
FCPA/Anti-Corruption Developments: 2023 Year in Review
April 12, 2024
By: Iris E. Bennett, Rachel B. Peck, Emily L. Shook, Kane Smith
Steptoe Investigations & Enforcement Blog
Disruptive Technology Strike Force: Year in Review
March 7, 2024
Client Alerts
AML Program Requirements for Investment Advisers: FinCEN’s Proposed Rulemaking
February 16, 2024
By: Andrew C. Adams, Coy Garrison, Jack R. Hayes, David M. Stetson, Evan T. Abrams, Sophia Breggia, Vito Arethusa
Client Alerts
Criminal Enforcement and Investigations: Key Considerations in the EU and the UK in 2024
January 22, 2024
By: Zoe Osborne
Press Releases
Chambers Greater China Region 2024 Recognizes Steptoe Practices and Lawyers
January 19, 2024
Steptoe Investigations & Enforcement Blog
January 19, 2024
Events
Webinars
Quarterly Investigations & Enforcement Update Webinar
January 25, 2024
Speakers: Jason Abel, Iris E. Bennett, Lee Berger, Christopher R. Conte, Amba M. Datta, Stacie R. Hartman, Lucinda A. Low, John J. Kavanagh, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
An Insider's Perspective on DOJ with Andrew Adams
November 8, 2023
Speaker: Andrew C. Adams
Webinars
Investigations & Enforcement Webinar Series
October 19, 2023
Speakers: Andrew C. Adams, Jason Abel, Iris E. Bennett, Christopher R. Conte, Stacie R. Hartman, Patrick F. Linehan, Lucinda A. Low, John J. Kavanagh, Zoe Osborne, Wendy Wysong
Seminars & Events
Global Trade and Enforcement Symposium in Hong Kong
June 1, 2023
Speakers: Renato Antonini, Yongqing Bao, Brigida Benitez, Brian G. Burke, Ali Burney, Henry Cao, John Caracappa, Boyd Cloern, Robyn C. Crowther, Brian J. Fleming, Coy Garrison, Stacie R. Hartman, Zoey Hong, Stanley C. Kuo, Amy J. Lentz, Michelle L. Levin, Patrick F. Linehan, Lucinda A. Low, Jamie Lucia, Alexandra Melia, Cáitrín McKiernan, Eva Monard, Darryl Nirenberg, Gwendolyn Prothro Renigar, Angus Rodger, Guy Soussan, David M. Stetson, Grace Wang, Philip R. West, Charles Whiddington, Wendy Wysong, Lin Yang, Bo Yue, Wilson Zhao
Webinars
Investigations & Enforcement Webinar Series
April 27, 2023
Speakers: Jason Abel, Christopher R. Conte, Amba M. Datta, Stacie R. Hartman, John J. Kavanagh, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Investigations & Enforcement Webinar Series
July 28, 2022
Speakers: Jason Abel, Iris E. Bennett, Amba M. Datta, Coy Garrison, Lucinda A. Low, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Investigations & Enforcement Webinar Series
April 21, 2022
Speakers: Iris E. Bennett, Christopher R. Conte, Stacie R. Hartman, Paul R. Hurst, Lucinda A. Low, Alexandra Melia, Michael Campion Miller, Wendy Wysong, Rachel B. Peck
Webinars
Anti-Corruption Initiatives and Enforcement in the Asia-Pacific Region
March 24, 2022
Speakers: Lucinda A. Low, Wendy Wysong, Bo Yue
Webinars
Investigations & Enforcement Webinar Series
January 27, 2022
Speakers: Jason Abel, Iris E. Bennett, Christopher R. Conte, Stacie R. Hartman, Paul R. Hurst, Patrick F. Linehan, Lucinda A. Low, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Why Do You (Really) Need to Consider Data Privacy in Cross-Border Investigations?
December 2, 2021
Speaker: Zoe Osborne
Resources
Client Alerts
FCPA/Anti-Corruption Developments: 2021 Year in Review
February 15, 2022
By: Iris E. Bennett, Lucinda A. Low, Rachel B. Peck, Brigida Benitez, Zoe Osborne, Wendy Wysong, Jingchun (Cherry) Huang, Samantha McCarthy, James M. Purce, Lin Yang, Bo Yue, Wilson Zhao, Joshua Dupre (law clerk), Zhaoxi Zhang (international paralegal)
Client Alerts
The Top Ten Asia-Pacific FCPA Enforcement Actions of 2020
January 27, 2021
By: Wendy Wysong
Client Alerts
FCPA/Anti-Corruption Developments: 2020 Year in Review
January 19, 2021
By: Lucinda A. Low, Zoe Osborne, Brigida Benitez, Alexandra Baj, Christopher R. Conte, Alexandra Melia, Ali Burney, Fernando Q. Merino, Wendy Wysong, Rachel B. Peck, Jefferson Klocke, Veronica Ganzitti, Jingchun (Cherry) Huang, Troy Shephard, Lin Yang, Bo Yue, Lucas Caiado (International Regulation & Compliance Intern), Jordan Cannon (Law Clerk), Marcia Pulcherio (International Trainee)
Client Alerts
World Bank COVID-19 Emergency Financing: Seizing Opportunities While Avoiding Pitfalls
January 6, 2021
By: Brigida Benitez
Client Alerts
Assessing the Impacts of Executive Order 13936 on Hong Kong's Status, One Month Later
August 25, 2020
By: Alexandra Baj, Ali Burney, Eric C. Emerson, Edward J. Krauland, Michelle L. Levin, Patrick F. Linehan, Meredith Rathbone, Wendy Wysong, Martin Willner, Jacob Nelson (International Trade Assistant)
Client Alerts
Top Ten Changes to the DOJ/SEC FCPA Resource Guide
July 20, 2020
By: Lucinda A. Low, Christopher R. Conte, Brigida Benitez, Wendy Wysong, Ali Burney, Jefferson Klocke
Client Alerts
DOJ Updates Corporate Compliance Program Guidance, Emphasizes Role of Data
June 4, 2020