FCPA/Anti-Corruption

Over the years, Steptoe has assisted many companies – US and foreign, their foreign affiliates, and individuals – in effectively managing risks arising under the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws in their trade and investment activities. Our practice encompasses both preventive and remedial services as well as the representation of companies and individuals before key enforcement agencies. We have extensive experience in emerging markets, including Latin America, China, Southeast Asia, the Middle East and Africa, and the former Soviet Union, which often involve government or quasi-governmental participation.

In serving our clients’ needs in the anti-corruption area, Steptoe fields a deep and broad team that includes resources from senior partners to junior associates, all of whom are focused on anti-corruption matters as the principal (and in some cases exclusive) emphasis of their practice. In addition to their experience in private practice, our lawyers' governmental experience includes service in the Department of Justice (DOJ), the staff of the Securities and Exchange Commission (SEC), and the Permanent Subcommittee on Investigations of the US Congress. We represent companies before the DOJ, SEC, World Bank Sanctions Board, and other bodies, and have performed special board committee investigations and internal investigations for companies, boards of directors, audit committees, and special litigation committees. Our principal resources are based in Washington, DC, San Francisco, London, and Hong Kong. Our team members in the Beijing and Brussels offices also provide important regional insight and support on issues that affect both compliance and investigations.

We are client-focused and seek practical and compliant solutions. Our experience around the globe allows us to make informed judgments about issues that arise in both the preventive and remedial sides of our work, and to handle matters with efficiency. Some of our clients are "one-off" (for example, when there is need for independent advice, investigation, or enforcement defense), but other relationships go back many years.

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

Steptoe lawyers have held and hold leadership positions in the Coalition for Integrity (formerly Transparency International USA) and in bar committees on corruption and money laundering, have testified before US Congress on anti-corruption issues, and have served on US delegations to the Organisation for Economic Co-operation and Development (OECD) Working Group on Bribery and the Organization for Security and Co-operation in Europe (OSCE). They write and speak extensively on cutting edge issues under the FCPA and related laws.

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

The services of Steptoe's FCPA/Anti-Corruption team include the following:

Compliance. Providing global anti-corruption compliance program development and implementation, including risk and gap assessments, drafts of policies and procedures, training, benchmarking, continuous improvement and advice regarding best practices.
Third Parties. Conducting due diligence and audits on third parties, advising on risk mitigation strategies, training, and advising on other steps to manage the central area of third-party risk.
M&A. Counseling on appropriate due diligence and risk mitigation measures, and representation of both buyers and sellers in M&A transactions.
Joint Ventures. Advising on and conducting due diligence, safeguards, and other mitigation measures.
Foreign Operations. Counseling and strategic support on foreign operational issues, including charitable and political contributions, gifts and entertainment, hiring issues, government support, payments and other operational challenges, including security support (and related business and human rights compliance issues), third-party issues, solicitation, books and records and other accounting issues, and local law prohibitions.
Opinions and Reviews. Providing legal opinions, business review letters, and regulatory guidance on specific transactions, offset requirements and third-party agency arrangements, and advice and representation with respect to the DOJ Opinion Procedure.
Voluntary Disclosures. Counseling and representation on voluntary disclosures to the US and other authorities; advice on collateral regulatory regimes pertaining to marketing activities, sales commissions, corporate governance (Sarbanes-Oxley/whistleblowers/Dodd-Frank), anti-money laundering laws and regulations, tax issues, and political contributions.
Internal and Government Investigations. Conducting internal investigations in response to whistleblower or other allegations on behalf of management or the board; responding to government investigations and inquiries, including voluntary requests for information, subpoenas, and the like; and dealing with stakeholders including external auditors, financiers, investors, and others.
Negotiated Resolutions. Negotiating deferred and non-prosecution agreements and pleas, and declinations under the FCPA Corporate Resolutions Policy of the DOJ.
Criminal and Other Proceedings. Defending clients of charges in criminal and civil/administrative proceedings, including World Bank sanctions proceedings.
Local Laws. Identifying and supervising 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.
Collateral Disputes and Whistleblower Matters. Assisting clients in resolving local disputes, arbitration, and litigation arising from FCPA compliance requirements and shareholder derivative complaints, and addressing whistleblower issues.
Monitorships. Assisting clients with the selection of monitors, supporting clients undergoing monitorships, and serving as monitors.
World Bank Sanctions Process. Counseling and representation in World Bank and other international financial institution investigations, sanctions proceedings, negotiated resolutions, cross-debarment matters and other collateral consequences, and voluntary disclosures.

Understanding local law is an increasingly important element in any effective global anti-corruption program. Steptoe has created the International Anti-Corruption Law Guide to meet this challenge. The guide offers web-accessible compliance reports that provide corporate subscribers and their employees with detailed information on local anti-corruption laws around the globe. Currently, 47 countries are included.

Our resources in other areas of international regulatory compliance (for example, export controls and economic sanctions) allow us to provide advice and support to clients on issues that may arise in the course of their international operations.

Industries

Aviation and transportation
Chemicals
Computer hardware and software
Consulting and other professional services
Defense
Energy
Engineering and construction
Entertainment and leisure
Extractive, including oil and gas, mining, and related services
Financial services, including private equity, hedge funds, and insurance
Hospitals and healthcare
Manufacturing
Pharmaceutical and medical devices
Telecommunications services and equipment
Retail

Noteworthy

Global Investigations Review (GIR) 100, Top 30 Firms for Investigations Worldwide (2015-2023)
Chambers Asia-Pacific, International Trade/WTO, Asia-Pacific Region (2009-2023)
Chambers Asia-Pacific, International Trade/WTO, China (2011-2022)
Chambers Greater China, Corporate Investigations/Anti-Corruption (2024)
Chambers Global, International & Cross-Border Capabilities, International Disputes & Regulation, US (2019-2025)
Chambers Global, Corporate Investigations/Anti-Corruption, (International Firms), China (2021-2025)
Chambers Global, Corporate Crime & Investigations, US (2017-2025)
Chambers Global, Investigations & Enforcement: International & Cross-Border, US (2020-2025)
Chambers Global, Disputes, International & Cross-Border Capabilities, US (2019-2025)
Chambers Global, FCPA, US (2017-2025)
Chambers Global, Corporate Investigations: Anti-Corruption, Global (2015-2018, 2022, 2025)
Chambers Global, Corporate Crime & Investigations (2025)
Chambers Latin America, Corporate Crime & Investigations: Latin America-wide (2016-2018)
Chambers USA, FCPA, Nationwide (2014-2024)
Chambers USA, Corporate Crime & Investigations, Nationwide (2015-2023)
Legal 500 Asia Pacific, Regulatory: Anti-Corruption and Compliance, Hong Kong (2021-2024)
Legal 500 Latin America, the International Firms: Compliance and Investigations (2023)
Legal 500 UK, Risk advisory: Regulatory investigations and corporate crime (2012-2019, 2022-2023)
China Law & Practice, Shortlisted, International Firm of the Year: Regulatory & Compliance (2018, 2021-2022)
China Business Law Journal, China Business Law Award: Anti-Bribery & Compliance (2015, 2018)

Professionals

Andrew C. Adams

Andrew Adams, a New York partner, advises companies and individuals in the areas of government and internal investigations, corporate governance, and white collar and regulatory matters. His practice...

Partner

Blockchain & Cryptocurrency, Financial Services, Financial Regulatory Compliance & Policy, White-Collar Defense

New York
+1 212 957 3081

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Lindsay B. Arrieta

Lindsay Arrieta is Of Counsel in Steptoe's Investigations and White-Collar practice, based in the firm’s Washington, DC office. Her practice focuses on advising clients on anti-corruption and...

Of Counsel

Independent & Internal Investigations, Monitorship, FCPA/Anti-Corruption, White-Collar Defense

Washington, DC
+1 202 429 3904

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Alexander Avery

Alex is an experienced trial lawyer who litigates complex civil matters involving fraud, contract, fiduciary duty, conversion, trade secret misappropriation, intellectual property, and unfair...

Associate

Commercial Litigation, Insurance & Reinsurance, Financial Services, Financial Services Litigation

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Alexandra Baj

Alexandra Baj heads Steptoe's International Trade and Regulatory Compliance group. She advises on export controls and economic sanctions laws and regulations, anti-corruption investigations and...

Partner

Export Controls, Economic Sanctions, Trade Remedies, Trade Policy & Negotiations

Washington, DC
+1 202 429 6478

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Brigida Benitez

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...

Partner and General Counsel

Independent & Internal Investigations, FCPA/Anti-Corruption, Global Anti-Corruption Insights: FCPA Years in Review, Commercial Litigation

Washington, DC
+1 202 429 6261

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Iris E. Bennett

Iris Bennett has more than two decades of experience representing companies and individuals in the defense and resolution of criminal and civil investigations by the U.S. DOJ and other U.S. agencies....

Partner

FCPA/Anti-Corruption, Independent & Internal Investigations, White-Collar Defense, Fraud & False Claims Act

Washington, DC
+1 202 429 8125

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Brian G. Burke

Brian Burke, a Chambers ranked Partner, advises clients on regulatory investigations, internal investigations and compliance counseling. His practice focuses on conduct in Asia-Pacific relating to...

Partner

FCPA/Anti-Corruption, Independent & Internal Investigations, Anti-Money Laundering, Economic Sanctions

New York
+1 212 378 7565

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Ali Burney

Ali Burney's practice focuses on representing clients in the Asia-Pacific region on matters related to US national security laws (incl. US economic sanctions and export controls), the US Foreign...

Partner

Economic Sanctions, Export Controls, FCPA/Anti-Corruption, Anti-Money Laundering

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Spencer Busby

Spencer Busby represents financial institutions, public companies, accounting firms, and other regulated entities in regulatory enforcement matters, internal investigations, and criminal defense...

Associate

Securities Enforcement, White-Collar Defense, FCPA/Anti-Corruption, Independent & Internal Investigations

New York
+1 212 378 7534

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Zihan Chen

Zihan Chen focuses his practice on conducting independent and internal investigations for multinational companies and providing advice on various compliance topics. He has advised and assisted clients...

Registered Foreign Lawyer

White-Collar Defense, Independent & Internal Investigations, FCPA/Anti-Corruption