Background - Practices (Details)

Anti-Corruption, Foreign Corrupt Practices Act (FCPA) & U.K. Bribery Act

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Representative Engagements

  • Assisted with a global information technology company with an internal investigation at its Costa Rica facility regarding employee conduct that may had violated the foreign corrupt practices act.
  • We conducted an internal investigation of FCPA issues for Ralph Lauren Corporation in Argentina. We self-reported the matter to both SEC and DOJ and orchestrated all remediation efforts, including risk assessments, compliance and training review, and implementation. We successfully negotiated unprecedented dual NPAs with both agencies, which included substantially discounted monetary penalties, and we convinced both the DOJ and SEC not to impose a corporate monitor. Finally, we drafted and presented annual NPA compliance reports to both agencies over the course of a two-year reporting term, which concluded in April 2015.
  • Provided counseling and assisted with an internal investigation of potential FCPA issues at their operations in Peru and Chile. The investigation included interviews, document collection and review, compliance policy assessment, coordination with local Peruvian counsel, forensic accounting support and a potential risk assessment.
  • Provided FCPA, sanctions and related counseling with respect to potential transactions/corporate structure in Mexico for an energy company.
  • Provided FCPA counseling to an aerospace company’s Mexico subsidiary.