Government & Internal Investigations

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 in need of outside counsel to handle government investigations, 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), FBI, DHS, Treasury Department, IRS, FTC, FERC, and the New York County District Attorney’s Office, as well as the UK’s Serious Fraud Office.  We are recognized by leading legal directories and publications – including Chambers USA, The Legal 500, Benchmark Litigation, and Law 360 – for our preeminence in corporate criminal defense and investigations.  We have also been recognized by the National Law Journal as the Washington Legal Department of the Year in White-Collar Crime.

We conduct independent investigations for boards of directors and trustees and board committees and internal investigations for public and privately-held companies.  We also represent public and private companies in proceedings before the DOJ, the SEC, state government entities, congressional committees, and other US or foreign agencies and regulators.  Steptoe lawyers provide crisis management advice relating to every facet of the modern financial crisis, and 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 design and implement remedial and preventive measures, enhance compliance programs and controls, and provide business and governance counseling and guidance.

We have particular experience conducting investigations relating to financial and securities fraud, FCPA, ethics and anti-corruption, False Claims Act and other government contract issues, healthcare fraud, antitrust, export controls, money laundering/BSA matters, and proceedings by the FTC, FERC, World Bank and other international financial institutions, and other regulatory agencies.

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.  Many of our partners are also bilingual and fluent speakers of several foreign languages.

Our judgment and deep law enforcement and government experience gives us unique credibility and effectiveness in dealing with law enforcement and other government agencies, along with the ability to scope investigations properly and economically for our clients.  At Steptoe, we don’t do “run away” investigations, and we are sensitive to the disruptions and collateral consequences that such investigations may cause.  Our team excels in conducting complex, multi-jurisdictional investigations while maintaining our focus on the key issues under review.

For these reasons, many of the nation’s highest profile institutions turn to Steptoe for independent investigations or corporate representation in government proceedings.  

Representative Matters

  • Steptoe conducted an independent investigation on behalf of the Board of Pilot Flying J, the largest travel center and diesel fuel provider in the United States, in connection with a criminal investigation by the Department of Justice into allegations that the company defrauded some of its trucking company customers.
  • Steptoe led an independent investigation of allegations of public corruption and pay-to-play practices at CalPERS, the largest state pension public fund in the United States, which resulted in more than $200 million in related fee reductions for the fund as well as other governance and financial safeguards and related changes to California state law.  The investigation was completed amidst related investigations and actions by state and federal prosecutors and securities regulators and intense media scrutiny.
  • Steptoe represented a publicly-traded offshore drilling contractor in connection with a DOJ and SEC investigation of potential FCPA violations in multiple foreign operations, prompted by a Dodd-Frank whistleblower who formerly held a control position in the company.  Based on Steptoe’s multi-jurisdictional internal investigation, both agencies terminated their investigations without enforcement action, and in doing so praised the thoroughness of the Steptoe investigation and the company’s compliance program, on which Steptoe also advised.
  • Steptoe conducted an internal investigation for Tidewater Inc., a leading oil field services company, and represented the company before the DOJ and the SEC in an FCPA investigation of payments to government officials in multiple countries in sub-Saharan Africa and Southeast and Central Asia.  Steptoe was able to reach a resolution with the government that avoided charges against the company, and has provided ongoing compliance advice to Tidewater on its anti-corruption program and specific transactional and operational issues.
  • Steptoe conducted an internal investigation on behalf of one of the largest energy companies in the United States into allegations that the company had provided misleading information to the Federal Energy Regulatory Commission (FERC).
  • Steptoe conducted an internal investigation for a government contractor relating to alleged gratuities provided to government officials.  We assisted the client in making a disclosure to the agency's IGs and in responding to the IG’s investigation of the matter, which included employee interviews.  Steptoe also worked with the client to develop additional compliance policies, procedures and employee training programs relating to this issue. 
  • Steptoe represents one of the nation’s leading financial institutions in connection with ongoing civil, criminal, and congressional investigations centered on AML/Bank Secrecy Act (BSA) compliance. This representation has embraced both systemic issues of devising and implementing practices and policies to meet with go-forward regulatory approval, and disclosure and enforcement issues in connection with legacy systems and particular historical transactions. In addition, we have assisted in a broad range of internal investigatory work. Our work has brought Steptoe lawyers in close contact and coordination with the full community of regulatory, congressional, and criminal authorities.
  • Steptoe represented Japan Airlines in a criminal antitrust investigation before the Antitrust Division of the DOJ.  In addition, we represented the company in a European Commission investigation into international passenger services between Europe and Japan, and defended them in the airfreight cartel investigation before the European Commission and the Swiss Competition Authority.
  • Steptoe partners served as special counsel to the Board of the Bank One Funds, whose investment adviser was named in the New York Attorney General’s first mutual fund market-timing complaint.
  • Steptoe partners served as special counsel to the Board of the AmSouth Funds, whose adviser was "Adviser A" in the SEC’s landmark action against BYSYS Fund Services and others for mutual fund marketing kickbacks.
  • Steptoe lawyers defended one of the country's principal defense contractors in serial government criminal, administrative and civil investigations growing out of a qui tam complaint about the provision of countermeasures used on the B-1 Bomber and F-15 Fighter.  Once unsealed, the relator's claims were dismissed, but other issues arising from the government investigation led the government to intervene to pursue other claims.  Ultimately, three grand juries failed to return indictments against the company or any individuals, the administrative investigation was abandoned, and the civil claims were settled favorably.

Noteworthy

  • Global Investigations Review (GIR) 100, Top 30 Firms for Investigations Worldwide, 2015-2016
  • Chambers Global, Corporate Investigations: Anti-Corruption (Global), 2015-2017
  • Chambers USA, FCPA (Nationwide), 2014-2017
  • Chambers USA, Corporate Crime & Investigations (Nationwide), 2015-2017
  • Chambers Latin America, Fraud & Corporate Investigations: Latin America-wide, 2016-2017
  • China Business Law Journal, China Business Law Award: Compliance and Anti-Corruption, 2015

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