Anti-Corruption & Foreign Corrupt Practices Act
Anti-Corruption & Foreign Corrupt Practices Act
Our team has unsurpassed experience in counseling and defending U.S. and foreign companies and individuals in matters relating to the U.S. Foreign Corrupt Practices Act and similar anti-corruption laws. We are frequently contacted when a potential corruption issue arises, and are go-to counsel for investigations and enforcement proceedings before the U.S. Department of Justice (DOJ), the Securities & Exchange Commission (SEC) and the Multilateral Development Banks, including the World Bank. In addition, we advise clients considering transactions in high-risk markets or with business partners with high anti-corruption risks. We also counsel clients who are designing compliance programs and in conducting risk assessments.
Awards & Recognition
Paul, Weiss Ranked by Global Investigations Review in 2022 “GIR 30”
Paul, Weiss was ranked for the third consecutive year by Global Investigations Review in its annual “GIR 30” list, which recognizes the best law firms for complex multijurisdictional corporate investigations.
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FCPA Enforcement and Anti-Corruption Developments: 2021 Year In Review
- Walter Brown
- Jessica S. Carey
- Roberto Finzi
- Harris Fischman
- Michael E. Gertzman
- Roberto J. Gonzalez
- Melinda Haag
- Joshua Hill Jr.
- Michele Hirshman
- Donna Ioffredo
- Brad S. Karp
- Loretta E. Lynch
- Mark F. Mendelsohn
- Lorin L. Reisner
- Jeannie S. Rhee
- Theodore V. Wells Jr.
- Kaye N. Yoshino
- Farrah R. Berse
- Peter Jaffe
- Justin D. Lerer
- Anti-Corruption & FCPA
- Economic Sanctions & AML
- Financial Institutions
- Internal Investigations
- Litigation
- White Collar & Regulatory Defense
- Miguel Zamora
- Jennifer K. Corcoran
- Robert Klein
- Benjamin J. Shack Sackler
In this review of anti-corruption enforcement and policy developments over the past year, we examine the noteworthy decline in enforcement and the proliferation of substantive recent policy developments that signal rising enforcement in the coming years.
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Mark Mendelsohn Speaks at the ABA’s 37th National Institute on White Collar Crime
Litigation partner Mark Mendelsohn spoke at the American Bar Association’s 37th National Institute on White Collar Crime.
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DOJ Awards FIFA Foundation $201 Million in Restitution as Compensation for Criminal Activities of Former Football Officials
Paul, Weiss represented FIFA in its successful application for remission from the U.S. Department of Justice as compensation for losses the organization suffered as a victim of decades of corruption schemes by former football officials.
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Dave Curran and Mark Mendelsohn Co-Author ESG Column in ALM Corporate Counsel
Sustainability & ESG Advisory Practice Co-Chair Dave Curran and litigation partner Mark Mendelsohn co-authored a column, “Pressure-Testing Your ESG Commitments,” in ALM Corporate Counsel on November 3.
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Eni S.p.A. Agrees to Resolve FCPA Charges As Controlling Minority Shareholder of Saipem S.p.A.
On April 17, 2020, the U.S. Securities and Exchange Commission (“SEC”) announced that it had resolved charges against Eni S.p.A., an Italian headquartered multinational oil and gas company, for violations of the recordkeeping and internal accounting controls provisions of the Foreign Corrupt Practices Act (“FCPA”).
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FCPA Developments: Q3 2020
Despite COVID-related challenges, FCPA enforcement by the DOJ and the SEC continued at full speed in the third quarter of 2020. Enforcement activity included three corporate resolutions by the DOJ and four resolutions by the SEC, as well as FCPA charges, guilty pleas and sentences concerning nine individuals.
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DOJ 2020 Guidance for Evaluating Corporate Compliance Incorporates Feedback From Business and Compliance Communities
- Anti-Corruption & FCPA
- White Collar & Regulatory Defense
- Jessica S. Carey
- Roberto Finzi
- Harris Fischman
- Michael E. Gertzman
- Brad S. Karp
- Loretta E. Lynch
- Mark F. Mendelsohn
- Lorin L. Reisner
- Jeannie S. Rhee
- Richard C. Tarlowe
- Farrah R. Berse
- Peter Jaffe
- Justin D. Lerer
- Economic Sanctions & AML
- Cybersecurity & Data Protection
The DOJ’s Criminal Division released updated guidance regarding the manner in which prosecutors evaluate the effectiveness of corporate compliance programs. The guidance makes clear that companies should continuously update their programs; broadens the focus of third-party risk management; and underscores the importance of post-acquisition due diligence and compliance integration.
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Paul, Weiss Successfully Resolves FCPA Investigation for Westport Fuel Systems
Paul, Weiss represented Westport Fuel Systems, Inc. in its settlement with the SEC in a matter alleging violations of the Foreign Corrupt Practices Act in connection with a transaction involving Westport’s Chinese joint venture.
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Jeannie Rhee Joins Paul, Weiss From the Mueller Special Counsel's Office
Jeannie Rhee, a former U.S. Deputy Assistant Attorney General, is joining the firm as a partner in the Litigation Department.
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FCPA Enforcement and Anti-Corruption Developments: 2019 Mid-Year Review
- Anti-Corruption & FCPA
- Economic Sanctions & AML
- Financial Institutions
- Litigation
- White Collar & Regulatory Defense
- Roberto Finzi
- Harris Fischman
- Michael E. Gertzman
- Michele Hirshman
- Brad S. Karp
- Loretta E. Lynch
- Mark F. Mendelsohn
- Lorin L. Reisner
- Jeannie S. Rhee
- Theodore V. Wells Jr.
- Kaye N. Yoshino
- Farrah R. Berse
- Justin D. Lerer
Robust FCPA enforcement activity continued in the first half of 2019. The DOJ and the SEC—resolving four and five corporate enforcement actions, respectively—assessed a combined total of $1.5 billion in corporate penalties, of which $1.1 billion was assessed by the DOJ and $421 million by the SEC.
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Former U.S. Attorney General Loretta Lynch Joins Paul, Weiss
Loretta Lynch, the Attorney General of the United States from 2015 to 2017, has joined the firm as a partner in the Litigation Department.
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DOJ Issues New Policy on Coordination of Corporate Penalties to Address “Piling On”
- Anti-Corruption & FCPA
- Financial Institutions
- Litigation
- Securities Litigation
- White Collar & Regulatory Defense
- H. Christopher Boehning
- Susanna M. Buergel
- Jessica S. Carey
- Roberto Finzi
- Michael E. Gertzman
- Roberto J. Gonzalez
- Michele Hirshman
- Brad S. Karp
- Mark F. Mendelsohn
- Lorin L. Reisner
- Richard C. Tarlowe
- Theodore V. Wells Jr.
- Farrah R. Berse
- Peter Jaffe
- Justin D. Lerer
Yesterday, Rod Rosenstein, Deputy Attorney General of the U.S. Department of Justice, announced a new policy, in the form of an addition to the United States Attorneys’ Manual (“USAM”), concerning the coordination of corporate resolution penalties in cases involving penalties imposed by more than one regulator or law enforcement authority.
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How Regulators Are Assessing Corporate Compliance Programs
What makes an effective corporate compliance program? And how do regulators evaluate them? The U.S. Department of Justice recently issued guidance on evaluating the effectiveness of corporate compliance programs in criminal investigations.
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