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FCPA/Anti-Corruption

 

Over the years, Steptoe has counseled many companies—US and foreign, their foreign affiliates, and individuals—on the scope, meaning, and application of the FCPA and related laws, involving a wide spectrum of countries and issues. Our practice includes both preventive advice and counseling and investigations and enforcement work. Our practice is worldwide, and includes extensive experience dealing with trade and investment transactions in emerging markets, particularly in Latin America, China, West Africa, Southeast Asia, the Middle East, and the former Soviet Union, which often involve government or quasi-governmental participation.

In serving our clients' needs in the FCPA area, Steptoe draws on the resources of our lawyers in both our International Regulatory & Compliance and White-Collar Criminal Defense groups. In addition to their extensive experience in private practice, our lawyers' governmental experience includes service in the Department of Justice, the staff of the Securities and Exchange Commission, and the Permanent Subcommittee on Investigations of the US Congress. We have performed special board committee investigations and internal investigations for companies, boards of directors, audit committees, and special litigation committees. Our European offices also provide important insight (for example, on EU data protection laws and UK money laundering laws) and support.

Steptoe lawyers litigated the Kay case, one of the leading decisions to construe the FCPA's scope. Steptoe lawyers have also been involved and are currently involved in a number of recent FCPA investigations and enforcement actions involving the Middle East, Latin America, the former Soviet Union, Africa, and Asia. We have also been in the forefront of World Bank investigations and sanctions proceedings, and have experience with parallel proceedings in multiple jurisdictions.

Steptoe lawyers have held and hold leadership positions in Transparency International and in ABA committees on corruption and money laundering, have testified before the US Congress on anticorruption issues, and served on US delegations to the OECD and OSCE on corruption issues. They write and speak extensively on cutting-edge issues under the FCPA and related international laws.

For a number of years, lawyers in our practice have consistently received the highest ranking in Chambers USA and Chambers Global.

Steptoe's FCPA/Anti-Corruption Team offers the following services:

  • Provide compliance program development and implementation, including training, benchmarking, and best practices advice
  • Counsel with respect to the scope and extent of due diligence, risk mitigation, and audits on partners, consultants, representatives, and other third parties
  • Counsel and represent buyers and sellers in M&A transactions
  • Develop risk mitigation safeguards in a variety of transactional and dispute contexts
  • Draft legal opinions, business review letters, and regulatory guidance on specific corporate transactions, offset requirements, and third-party agency arrangements
  • Advise on collateral regulatory regimes pertaining to marketing activities, sales commissions, anti-money laundering laws and regulations, tax issues, and political contributions
  • Represent in Justice Department, SEC enforcement proceedings and investigations as well as collateral proceedings involving the US Congress, World Bank, and other US agencies
  • Identify and supervise counsel in foreign jurisdictions to obtain opinions on local law regarding gratuities provided to government officials and coordinate integrated advice on FCPA and local law issues
  • Assist clients in resolving local disputes, arbitration, and litigation arising from FCPA compliance requirements.

Understanding local law is an increasingly important element in any effective global anti-corruption program. Steptoe has created the International Law Guides to meet this challenge. The Guides offer web-accessible compliance reports that provide corporate subscribers and their employees with detailed information on local anti-corruption laws around the globe. Currently 28 countries are included, and 22 more countries are being added by the end of this year. A second tool will launch in 2012 to provide information on laws affecting the hiring, retention, and termination of sales representatives in countries around the world. Each country guide is developed by an attorney in the local jurisdiction, is updated each year and is carefully vetted for clarity and scope.

Industries

  • Extraction, includes oil and gas, mining, and oil field services
  • Telecommunications services and equipment
  • Manufacturers
  • Defense
  • Commercial airlines and transportation
  • Pharmaceutical
  • Hospitals
  • Financial services, including private equity
  • Insurance
  • Energy
  • Chemicals
  • Healthcare
  • Retail industries
  • Consulting, engineering, and other services
  • Computer hardware and software

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