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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.

Events

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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Client News

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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Publications

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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Publications

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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Publications

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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Publications

DOJ 2020 Guidance for Evaluating Corporate Compliance Incorporates Feedback From Business and Compliance Communities

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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Client News

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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Firm News

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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Publications

FCPA Enforcement and Anti-Corruption Developments: 2019 Mid-Year Review

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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Firm News

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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Publications

DOJ Issues New Policy on Coordination of Corporate Penalties to Address “Piling On”

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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Videos

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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