Overview
Brigida Benitez focuses on internal corporate investigations, global compliance and anti-corruption issues, and complex civil litigation. She draws on more than 30 years of experience representing clients in high-stakes, complex matters and helping them solve challenging problems that stem from business disputes, compliance issues, and employee misconduct. Brigida has represented a wide range of clients, including financial institutions, pharmaceutical companies, universities, international development firms, and individuals, as well as boards of directors and special litigation committees of public company boards.
Brigida has litigated high-profile cases in trial and appellate courts throughout the United States, including the US Supreme Court. She has conducted internal investigations relating to a variety of sensitive and business-critical issues, such as bribery and corruption under the Foreign Corrupt Practices Act (FCPA) and other anti-bribery laws, financial fraud, employee misconduct, ethics issues, codes of conduct violations, accounting irregularities, and whistleblower complaints.
Brigida has deep knowledge of the investigative and sanctions procedures of international financial institutions (IFIs). She represents clients in all phases of World Bank and Inter-American Development Bank (IDB) proceedings – audit and investigation, litigation of allegations, and arguments before the World Bank Sanctions Board and the IDB Sanctions Committee – and has advised clients on compliance with IFI anti-corruption guidelines. She also has represented clients before the Asian Development Bank, the African Development Bank, and the European Bank of Reconstruction and Development.
Before joining Steptoe, Brigida served as Chief of the Office of Institutional Integrity of the IDB, a senior management role reporting to the IDB President and the Audit Committee of the Board of Executive Directors. While at the IDB, Brigida oversaw investigations of fraud and corruption in IDB-financed activities, and implemented compliance policies and procedures relating to anti-corruption, anti-money laundering, offshore financial centers, and sanctions administered by the US Department of the Treasury's Office of Foreign Assets Control (OFAC). She helped develop the General Principles and Guidelines for Sanctions used by the IDB and the World Bank, and oversaw the implementation of the Agreement for Mutual Enforcement of Debarment Decisions, entered into by the IDB, the World Bank, and several other leading multilateral development banks.
In addition to her investigations and litigation practice, Brigida serves as Steptoe’s General Counsel and serves on the Firm’s Executive Committee.
Brigida is a past president of the DC Bar, the largest unified bar association in the United States, with more than 100,000 members worldwide. She has served as an adjunct professor at Georgetown University Law Center, where she taught a course on international business litigation and federal practice. She has been recognized by Hispanic Business magazine as a "Woman of the Year" and one of the "100 most influential US Hispanics," and by Latino Leaders magazine as one of the "25 Most Influential Hispanic Lawyers."
- District of Columbia
- Supreme Court of the United States
- Various Federal Circuit and District Courts
- J.D., Boston College Law School, 1993, cum laude; Editor-in-Chief, Boston College Law Review
- B.S., University of Florida, 1990, High Honors
Areas of Work
Representative Matters
Investigations
- Conducted independent investigation for 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 health care-related issues.
- Conducted investigation for public company involving allegations of improper accounting practices.
- Conducted investigation for multinational extractive company of alleged FCPA violations and commercial fraud in South America. Conducted all witness interviews in Spanish.
- Conducted investigation for multinational security company of alleged bribery by local partner in Middle East and South Asia.
- Conducted investigation for Mexican subsidiary of multinational financial institution regarding FCPA and related fraud issues. Conducted all witness interviews in Spanish.
- Conducted investigation of multinational corporation's operating companies in Argentina and Brazil involving alleged FCPA violations. Conducted all witness interviews in Argentina in Spanish.
- Conducted investigation for international financial institution relating to employee misconduct and ethics issues.
- Conducted investigation for large research institution in connection with claims of employee misconduct.
- Conducted internal review of admissions practices for large private university and recommendations for revisions to existing policies.
World Bank / IFI Sanctions Proceedings
- Represented international development firm in sanctions proceeding initiated by the World Bank’s Integrity Vice Presidency, which investigated and charged the firm with corruption in a World Bank-funded project. Sanctions and Debarment Officer recommended a six-year public debarment. Litigated charges and successfully argued case to World Bank Sanctions Board, which dismissed case and terminated sanctions proceedings, a rare outcome in these cases.
- Represented Japanese engineering company in World Bank investigation and sanctions proceeding involving allegations of fraud in projects in Asia and Latin America. Successfully argued case to World Bank Sanctions Board, resulting in a conditional non-debarment, allowing company to remain eligible for World Bank contracts.
- Represented South Asian technology company in enforcement and debarment proceeding involving allegations of fraud, collusion, and corruption before World Bank Sanctions Board.
- Represented Latin American audit firm in enforcement and debarment proceeding involving allegations of fraud before World Bank Sanctions Board.
- Represented former CEO of US company in enforcement and debarment proceeding involving allegations of corruption and fraud before IDB Sanctions Committee.
- Represented Spanish engineering company in enforcement and debarment proceeding involving allegations of fraud and obstruction before the World Bank Sanctions Board.
- Represented Chinese construction company in sanctions proceeding initiated by the Asian Development Bank, successfully negotiating a Resolution Agreement with the Office of Anti-Corruption and Integrity.
Speaking Engagements
- "Corporate Enforcement Priorities for Your Neighbor to the North: the Implications of Recent Developments in U.S. Anti-Corruption, Sanctions, and National Security Policy for Companies in Mexico," Private Program, Steptoe and Sanchez-DeVanny (Monterrey), May 16, 2024
- "US Government Enforcement Priorities and Policy Developments," International Chamber of Commerce México, February 28, 2024
- "Compensation Clawbacks in Practice: Legal and Compliance Experts Discuss the Real-Life Aftermath and New Lessons Learned," ACI's 17th Forum on the Foreign Corrupt Practices Act Houston, January 24, 2024
- "Navigating the High-Profile investigation," Pennsylvania Association of Criminal Defense Lawyers 2023 White Collar Practice Seminar, November 16-17, 2023
- "Latinas and the Path to Partnership," Hispanic National Bar Association's Region V, March 14, 2023
- Keynote speaker, ABA International Law Section Fall Conference, Madrid, Spain, September 2022
- Panelist, "Risky Business: Avoiding Ethical Pitfalls in Lateral Hiring," ABA Business Law Section Annual Meeting, September 2022
- "The New Face of Enforcement in Latin America," ACI’s 38thInternational Conference on FCPA, Washington, DC, December 1, 2021
- "Best Practices for Managing Anti-Bribery and Corruption Considerations in M&A," Lex Mundi Webinar, September 14, 2021
- "World Bank Fraud and Corruption Investigations," Keynote Address to New York Chapter of Association of Certified Fraud Examiners, February 24, 2021
- "Anticorruption Compliance in LATAM: Perspectives and Best Practices," Houston Bar Association International Law Section, February 11, 2021
- "Women and Diversity: Trends, Issues and Challenges in the Legal Profession," DC Bar Corporation, Finance and Securities Law Community Forum, Washington, DC, February 4, 2021
- "Special Interview with the FBI," ACI's Forum on the FCPA Houston, Houston, TX, January 30, 2020
- "Multinational Corporate Investigations," ABA Business Law Section Annual Meeting, Washington, DC, September 13, 2019
- Moderator, "What to Do If Your Third Parties Are Under Suspicion: How Multinationals are Tackling More Regional Enforcement, Scandals and Legislation," ACI's 35th International Conference on FCPA, Oxon Hill, MD, November 28, 2018
- "Global Cyber Security and Data Privacy - A Look at GDPR, Managing an International Privacy Program and Cross-Border Data Transfers," ABA Business Law Section Annual Meeting, Austin, TX, September 14, 2018
- Moderator, "Fellows at the Top: A Conversation with Current and Former Presidents of Diversity Organizations," 7th Annual LCLD Fellows Alumni Leadership Symposium, Los Angeles, CA, June 22, 2018
- "International Regulation and its Impact in Chile – Corruption, Anti-Money Laundering and Fraud," Santiago, Chile, April, 2018
- "Anti-Money Laundering, Counter-Terrorist Financing, Anti-Financial Crime US and Global Developments Update 2018," ABA Business Law Section Spring Meeting, Orlando, FL, April, 2018
- "Deconstructing the Myth of 'Machismo': Latin America's Leadership in Gender Equality," ABA Section of International Law Fall Meeting, Miami, FL, October 27, 2017
- Moderator, "'Brexiting' the UK Bribery Act and Trumping Up the FCPA: A Review of Current Administrations' Effects on Anti-Corruption Laws," ABA Business Law Section Meeting, Chicago, IL, September 14, 2017
- "Anti-Money Laundering Developments for Money Managers," ABA Business Law Section Meeting, New Orleans, LA, April, 2017
- "When Third Party Risks Warrant Walking Away - Red-Flag Scenarios and Interactive Discussions on Agents, Distributors and Intermediaries," Andean Summit on Anti-Corruption Compliance and Enforcement, Bogotá, Colombia, November 16, 2016
- "The Different Faces of Corruption," ACI's West Coast FCPA Enforcement & Compliance Conference, San Francisco, CA, October 18, 2016
- "Has the International Olympic Committee Risen Above Corruption?," Maryland Journal of International Law Corruption in International Sports Symposium, Baltimore, MD, October, 2016
- "International Money Laundering Developments," International Bar Association Transnational Crime Conference, Panama City, Panama, May 12, 2016
- "Spotlight on Brazil, Argentina, and Mexico," ACI's 5th Global Forum on Anti-Corruption Compliance in High Risk Markets, Washington, DC, July 16, 2014
- "Global Corruption and Bribery Risk," Global Strategic and Enterprise Risk Management Conference, New York, NY, June 5, 2014
- "Foreign Corrupt Practices: The Comparative Treatment in Brazil and the United States," Latin America Conference Hosted by US Chamber of Commerce Institute for Legal Reform, Miami, FL, May 1, 2014
- "Bribery and Corruption: Compliance and Enforcement Issues in Emerging Markets," International Bar Association Transnational Crime Conference, Istanbul, Turkey, April 3, 2014
- "Corruption Risk," The Conference Board, Managing Global Risk and Reputation to Your Company’s Advantage Seminar, New York, NY, December 11, 2013
- "Best Practices on How to Conduct an Internal Investigation," Corporate Counsel Women of Color Career Strategies Conference, Washington, DC, September 25, 2013
- "From a Culture of Corruption to a Culture of Compliance: Ensuring That Employees Are Engaged and Vested in Your Local Compliance Programs," Fourth Global Forum on Anti-Corruption, Washington, DC, July, 2013
- "Doing Business With Multilateral Development Banks," American University Washington College of Law, US and International Anti-Corruption Law Summer Program, Washington, DC, June 2013
News & Publications
Publications
The Legal and Compliance Implications of the Supreme Court's Snyder Decision
The Anti-Corruption Report
September 13, 2024
By: Brigida Benitez, Iris E. Bennett, Patrick F. Linehan, Nicholas P. Silverman
Press Releases
Brigida Benitez Appointed General Counsel of Hispanic National Bar Association
September 12, 2024
Media Mentions
Bloomberg Law Quotes Brigida Benitez in Article About SAP Bribery Case
January 12, 2024
Press Releases
Steptoe Receives Compliance and Investigations Practice Ranking in The Legal 500 Latin America 2024
October 26, 2023
Client Alerts
US Supreme Court Holds Race-Based University Admissions Programs Unconstitutional
June 30, 2023
By: Ryan P. Poscablo, Brigida Benitez, Eric Berman, Dwight J. Draughon, Jr., Patrick F. Linehan, Shannon Reid, Brittney Denley
Press Releases
Four Steptoe Lawyers Named to Lawyers of Color Law Firm Leaders Issue 2022
February 2, 2023
International Compliance Blog
December 14, 2022
By: Iris E. Bennett, Brigida Benitez, Patrick F. Linehan, Wendy Wysong
Press Releases
Steptoe Secures Win for Clients in Case Against Former Trump Advisor
September 2, 2022
Media Mentions
National Law Journal Covers Brigida Benitez's Appointment as Steptoe General Counsel
February 22, 2022
Resources
Client Alerts
FCPA/Anti-Corruption Developments: 2022 Year in Review
February 24, 2023
By: Iris E. Bennett
Client Alerts
FCPA/Anti-Corruption Developments: 2021 Year in Review
February 15, 2022
By: Iris E. Bennett, 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
FCPA/Anti-Corruption Developments: 2020 Year in Review
January 19, 2021
By: Zoe Osborne, Brigida Benitez, Alexandra Baj, Christopher R. Conte, Alexandra Melia, Ali Burney, Fernando Q. Merino, Wendy Wysong, Jefferson Klocke, 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
Top Ten Changes to the DOJ/SEC FCPA Resource Guide
July 20, 2020
By: Christopher R. Conte, Brigida Benitez, Wendy Wysong, Ali Burney, Jefferson Klocke
Client Alerts
FCPA/Anti-Corruption Developments: 2019 Year in Review
January 21, 2020
By: Brigida Benitez, Wendy Wysong, Zoe Osborne, Steven J. Barber, Alexandra Melia, Ali Burney, Fernando Q. Merino, Alexandra Baj, Jefferson Klocke, Troy Shephard, Lin Yang, Bo Yue
Client Alerts
World Bank Highlights Continued Enforcement Focus in Second Annual Sanctions System Report
October 28, 2019
By: Brigida Benitez
Client Alerts
FCPA/Anti-Corruption Developments: 2018 Year in Review
February 28, 2019
By: Brigida Benitez, William L. Drake, Alexandra Melia, Fernando Q. Merino, Alexandra Baj, Evan T. Abrams, Lin Yang, Bo Yue, Troy Shephard
Client Alerts
FCPA/Anti-Corruption Developments: 2017 Year in Review & 2018 Q1 Preview
April 12, 2018
By: Brigida Benitez, William L. Drake, Alexandra Baj, Evan T. Abrams, Galen Kast, Lin Yang, Bo Yue
Client Alerts
June 29, 2017
By: Brigida Benitez, Alexandra Melia, Stephanie W. Wang, Zhu (Judy) Wang, Bo Yue
Events
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, Zoey Hong, Stanley C. Kuo, Amy J. Lentz, Michelle L. Levin, Patrick F. Linehan, 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
October 18, 2022
Speakers: Brigida Benitez, Iris E. Bennett, Carlos Ayres, Bruno Maeda, Larry Walker
Webinars
June 17, 2021
Speakers: Brigida Benitez, Matthew Coleman, Eric C. Emerson, Meredith Rathbone, Vyacheslav Khorovskiy
Noteworthy
Legal Directories
- Global Investigations Review, "Women in Investigations: One Hundred Investigation Specialists From Around the World" (2018)
- Super Lawyers, Washington, DC, Litigation (2010, 2013-2021)
- Legal 500 Latin America: International Firms, Compliance and Investigations (2024)
- Legal 500 US, Dispute Resolution: General commercial disputes (2018)
- Legal 500 US, Litigation: International Trade (2013)
- Latinvex, Top 100 Female Lawyers (2016-2017)
- Latino Leaders Magazine, Top Latino Lawyers (2017, 2021-2022)
- Latino Leaders Magazine, 25 Most Influential Hispanic Lawyers (2015)
- Hispanic Business Magazine, 100 Most Influential US Hispanics (2016)
- Best Lawyers in America, Employment Law: Management (2013-2022)
- Washingtonian magazine, "Top 40 Lawyers Under 40" (2006)
Awards and Recognitions
- Quoted, "Trump's many civil cases won’t stop just because he's president. Here's what to know," CNN Politics, December 19, 2024
- National Pre-Law Diversity Initiatives, Inc, Diversity Champion Award (2017)
- Women's Bar Association of DC, Star of the Bar Award (2012)
- Hispanic Scholarship Fund Alumni Hall of Fame, Brillante Award (2011)
- Hispanic National Bar Association, "Latina Lawyer of the Year" (2006)
- Boston College Law School, 75th Anniversary Alumni Award (2006)
- Hispanic Bar Association of DC, Latina Leader Award (2008)
- Hispanic Business Magazine, "Woman of the Year" (2005)
- Mexican American Legal Defense & Educational Fund, Excellence in the Legal Profession Award, (2005)
- DC Bar Best Bar Project (2005)
Previous Employment
- Inter-American Development Bank, Chief, Office of Institutional Integrity (2010-2012)
- Georgetown University Law Center, Adjunct Professor (2011-2022)
Professional Affiliations
- Past President, DC Bar
- Member, American Law Institute
- Fellow, American Bar Foundation
- Board Member, Tahirih Justice Center; Chair, Audit Committee
- Council Member, Business Law Section, American Bar Association; Former Chair, International Business Law Committee
- Member, International Women's Forum of DC
- Member, Women's White Collar Defense Association
- Former Commissioner, American Bar Association Commission on Racial and Ethnic Diversity in the Profession
- Past President, Hispanic Bar Association of DC
- Former National Vice-President for External Relations, Hispanic National Bar Association
- Former Board Member, International Women’s Forum of DC
- Former Member, US District Court for the District of Columbia Grievance Committee
- Former Member, DC Circuit Judicial Conference Committee on Pro Bono Legal Services
- Former Member, Hearing Committee, DC Board on Professional Responsibility