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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.

Representative Engagements

Our experience in FCPA-related work includes representation of the following:

INVESTIGATIONS AND DEFENSE

Corporate Representations

Africa

  • A global producer of specialty chemical products in internal and government investigations involving alleged improper third-party payments in its operations in West Africa, including Chad, Burkina Faso, Mali and Ghana.
  • The Audit Committee of a publicly-traded mining company in an internal investigation of alleged improper transactions involving political party officials and a Black Economic Empowerment transaction.
  • A financial institution in a government FCPA and money laundering investigation involving Equatorial Guinea and Angola.
  • A major U.S. oil and gas company in an FCPA investigation involving Angola and Nigeria.
  • Represented Fichtner GmbH & Co. KG in its favorable settlement of a World Bank investigation in relation to sanctionable misconduct in the Southern Africa Power Market Project in the Democratic Republic of the Congo.

Asia-Pacific Region

  • JPMorgan Chase in the favorable resolution of an investigation conducted by various authorities, including the DOJ and SEC, into whether hiring practices in Asia complied with anti-corruption laws.
  • A company in the gaming and hospitality industry in a DOJ and SEC FCPA investigation in connection with the company's operations in China.
  • An international cruise line and its European subsidiary in connection with an internal investigation regarding business partners and hospitality issues in China.
  • A major publicly held U.S. food products company in an internal investigation of bribery allegations in China.
  • A U.S. financial institution in an internal investigation relating to alleged improper payments in its Indian subsidiary.
  • A global anti-corruption internal investigation for a Japanese trading company involving government tender projects in the UAE, Italy and Asia.
  • A major Hollywood motion picture studio and its parent company in connection with an SEC FCPA investigation regarding its film distribution activities in China and various payments in its India operations.
  • A major financial institution in an internal investigation concerning gift and entertainment expense activities involving state-owned and private clients in Japan and South Korea.
  • A major pharmaceutical company in an internal investigation concerning allegations of kickbacks, misuse of travel agencies, and improper payments and gifts to healthcare providers in China.
  • A financial software company in sanctions proceedings brought by the World Bank Vice Presidency for Integrity (INT) alleging corruption in connection with a Mongolian government tender and employee hiring. Though INT sought to debar our client from participation on World Bank contracts for a period of three years, Paul, Weiss persuaded the World Bank Sanctions Board to issue a private letter of reprimand without debarment or any prejudice to the client's eligibility to participate in World Bank-financed projects. That decision is the first published decision to impose a private letter of reprimand after concluding that a respondent had engaged in a sanctionable act.
  • A manufacturing and retail firm in an internal investigation concerning alleged improper payments by an affiliate to Chinese government-connected organizations.
  • A U.S.-listed medical device company in an investigation of potential FCPA concerns relating to its operations in China.

Europe

  • A large nonprofit organization that provides humanitarian relief and assistance overseas in securing a declination of prosecution from the DOJ, a complete victory for the organization. The organization was being investigated for potential violations of the FCPA in Central and Eastern European countries, including Russia, concerning payments made in connection with licensing, permitting, and security services.
  • Appointed by a multilateral development bank to act as an independent inquiry officer to investigate alleged solicitation of bribes in Russia by one of its directors.
  • A private Ukrainian technology company in connection with multiple sanctions proceedings before the World Bank arising from corruption, collusion, and obstruction allegations involving multiple World Bank-financed government tenders.
  • A multinational Fortune 500 company in an internal investigation concerning alleged improper third-party payments by one of its Eastern European subsidiaries.
  • A major financial institution in an SEC and DOJ investigation concerning alleged improper payments to senior executives of a client.

Latin America

  • A Fortune 100 retail company in an internal investigation concerning vendor and other third-party relationships involving operations in Mexico.
  • A mining company in an internal investigation concerning alleged improper payments made in connection with Bolivian licensing issues.
  • A private equity firm in connection with an internal investigation concerning alleged improper payments at a portfolio company in the oilfield services industry to Mexican government officials in connection with public tenders.
  • A commodity trading firm in connection with an internal investigation concerning alleged improper payments made by a joint venture partner to Venezuelan government officials in connection with state mandated inspections.
  • The U.S. subsidiary of a Japanese electronics company in connection with an investigation of bribery allegations in Mexico and Brazil.

Middle East

  • A major multinational lightweight metal manufacturer in the defense and resolution of SEC and DOJ investigations involving alleged improper payments through a middleman/distributor to officials in Bahrain.
  • A major television network in a DOJ FCPA investigation concerning its business relationship with an Egyptian government official.
  • The Audit Committee of a leading international commercial real estate firm in a DOJ and SEC FCPA investigation of alleged improper payments to an official with a Middle Eastern sovereign wealth fund in connection with the putative purchase of a skyscraper in Vietnam.

Individual Representations

  • An individual engaged by a major oil services company in DOJ and SEC investigations of potential FCPA violations in Indonesia and Nigeria.
  • A senior executive at a medical device company in DOJ and SEC investigations of potential FCPA violations in Brazil and Mexico.
  • Executives and managers of the Indian subsidiary of a multinational food and beverage conglomerate in connection with DOJ and SEC investigations concerning alleged improper payments in connection with licensing issues.
  • The general counsel of a public oil and gas drilling services company in connection with an internal investigation concerning alleged improper payments to employees of state-owned customers in Pakistan.
  • A senior compliance professional of a medical technology company in connection with a DOJ investigation concerning alleged improper payments in China.
  • A former senior executive in connection with an SEC and DOJ investigation concerning alleged improper payments in India.
  • A senior executive at a multinational metal company in an inquiry involving alleged unlawful payments to government officials in the Middle East.
  • A senior executive of a U.S. telecommunications company in SEC and DOJ investigations concerning charitable contributions in the Middle East.
  • A board member of a European telecommunications company in connection with allegations of bribery in Eastern Europe.
  • A former senior executive of a global producer of distilled beverages in connection with alleged FCPA violations.

COMPLIANCE COUNSELING AND DUE DILIGENCE

  • Advised on the design and implementation of a global anti-corruption compliance program for various Japanese trading companies.
  • Conducted a risk assessment and advised on enhancements to compliance program for a U.S. supermarket chain.
  • Provided compliance advice for an energy company in connection with a potential seed investment in Uganda.
  • Conducted third-party and transactional due diligence and provided anti-corruption compliance advice for a major U.S. film production studio.
  • Provide advice on improvements to an anti-corruption compliance program for a U.S. business outsourcing company.
  • Provide ongoing anti-corruption compliance advice and third-party and transactional due diligence for a major U.S. technology company.
  • Provide advice on the design and implementation of an internal anti-corruption compliance program for a global beverage company.
  • Provide day-to-day compliance advice, anti-corruption training, anti-corruption policy review and due diligence for a U.S. renewable energy company.
  • Conduct third-party diligence for a U.K. manufacturer of surveillance and security systems.
  • Numerous companies, private equity funds, and financial institutions in the design and implementation of anti-corruption compliance programs and training of boards of directors, senior executives, managers and personnel.

© 2019 Paul, Weiss, Rifkind, Wharton & Garrison LLP

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