Anti-Corruption and the Foreign Corrupt Practices Act

The current enforcement landscape has a clear emphasis on individual accountability, large-scale corruption, and sophisticated concealment tactics.

As expectations around third-party risk, executive oversight, and compliance infrastructure continually evolve, companies should seek a proactive, data-informed, and globally aligned approach to managing potential exposure.

Enforcement experience that safeguards your business

Our attorneys bring deep insight into enforcement operations. With a bench of more than 40 former enforcers – including a former FCPA Unit Supervisor and FBI FCPA Unit Special Agent, Assistant US Attorneys, and federal and state prosecutors – our team has handled significant anti-corruption and FCPA matters across industries in over 100 countries. We provide strategic guidance on the full spectrum of criminal, civil, and regulatory risk and how to manage the often conflicting demands of both US and global enforcement agencies.

Comprehensive support across the anti-corruption lifecycle

We leverage extensive in-house compliance and investigative experience to deliver end-to-end support for businesses navigating anti-corruption risk – from compliance program design and strategic counseling to internal investigations and regulatory defense.

• Represented Deere & Company in a Department of Justice (DOJ) and Securities and Exchange Commission (SEC) FCPA investigation involving alleged bribes to government officials and private employees in Thailand.


• Represented a telecommunications company in a DOJ FCPA investigation into allegations of a USD30 million bribe at the Venezuelan subsidiary level. We favorable resolved the investigation without a corporate parent resolution and without a monitor.


• Represented a global consumer company in an FCPA and local law investigation involving the use of third-party vendors to assist in the company’s Brazil operations. We persuaded DOJ and SEC to closed their files without any enforcement action and resolved local issues in Brazil.


• Represented a NASDAQ-listed technology company in DOJ and SEC investigations in connection with alleged FCPA violations related to a USD1 billion tender in South Africa. DOJ declined to prosecute, and the SEC issued a “No Action” letter.


• Represented a European aerospace and defense company in a multi-year DOJ investigation involving alleged bribery and export control violations. Achieved a favorable deferred prosecution agreement (DPA) for the company as part of the coordinated anti-corruption resolution with UK and French criminal enforcement authorities and continued with the successful completion of investigation and compliance DPA obligations.


• Represented a US company under the FCPA pilot program, resulting in a DOJ declination with disgorgement and conditional non-debarment from the World Bank.


• Represented the audit committee of Cognizant Technologies Solutions Corp. in internal and government investigations regarding potential FCPA violations. Cognizant resolved both DOJ and SEC actions, notably receiving a declination of prosecution letter from DOJ on the same day DOJ announced the indictments of Cognizant’s former president and former general counsel.


• Represented several global life science companies in internal investigations and conducted reviews across their operations worldwide, particularly in developing and emerging markets such as China, Southeast Asia, the Middle East, and South America.


• Represented a global telecommunications company in a multi-year FCPA investigation into possible FCPA violations conducted by US authorities involving allegations that the company gave civil servants hundreds of tickets to the World Cup soccer finals. We negotiated a favorable resolution with the SEC, including a relatively modest $4.1 million penalty, and no action was taken by the DOJ.