Expanded Bio
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Mark F. Mendelsohn


Tel: 202-223-7377
Fax: 202-204-7377

2001 K Street, NW
Washington, DC 20006-1047

A partner in the Litigation Department, Mark Mendelsohn is co-chair of the FCPA Group, and a member of the White Collar Crime and Regulatory Defense, Internal Investigations, and Securities Litigation Practice Groups. Prior to joining Paul, Weiss, Mark served as the deputy chief of the Fraud Section of the Criminal Division of the United States Department of Justice (DOJ), and is internationally acknowledged and respected as the architect and key enforcement official of DOJ’s modern Foreign Corrupt Practices Act (FCPA) enforcement program.


Mark's practice emphasizes white collar criminal matters, internal corporate investigations, and compliance counseling. He regularly represents clients in FCPA and corruption-related internal investigations, designing and implementing compliance programs, transactional anti-corruption diligence, and responding to and defending against government investigations, prosecutions, and trials on behalf of both business entities and individuals.

Mark's experience includes representation of the following:

Public and Private Companies

  • a public real estate and financial services company in connection with an internal FCPA investigation of conduct in its Indian subsidiary;
  • a private financial services firm in connection with an internal FCPA investigation of conduct in its China affiliate;
  • a commodities trading company in connection with an internal FCPA investigation of conduct in its joint venture in a South American country;
  • a private equity fund in connection with an anti-corruption risk assessment and the design and implementation of an anti-corruption compliance program;
  • a technology company in connection with an anti-corruption risk assessment and the design and implementation of an anti-corruption compliance program;
  • a global non-profit organization in connection with a DOJ FCPA investigation of its operations in Eastern Europe and the former Soviet Union;
  • a multilateral development bank in connection with an internal investigation of corruption by one if its directors; and
  • numerous companies, private equity funds, and financial institutions in connection with third-party and transactional diligence in Africa, Asia, Europe, North, Central and South America, and the Middle East.

Individual Executives

  • the general counsel of a public oil and gas drilling services company in connection with an internal FCPA investigation; and
  • executives and managers of the Indian subsidiary of a listed U.S. company in connection with DOJ and SEC FCPA investigations.

As deputy chief of the Fraud Section from 2005 to 2010, Mark was responsible for overseeing all DOJ investigations and prosecutions under the FCPA, and for supervising a team of trial attorneys with respect to investigations and prosecutions of a wide variety of federal white collar crimes including money laundering, mail and wire fraud, procurement fraud, Arms Export Control Act and International Traffic in Arms Regulations (ITAR) violations, and violations of economic and trade sanctions laws and regulations, including with respect to the United Nations Oil for Food Program. During his tenure, Mark handled hundreds of voluntary disclosures of illicit corporate payments, worked closely with attorneys in the Division of Enforcement at the U.S. Securities and Exchange Commission, helped establish and worked closely with the Federal Bureau of Investigation's FCPA squad at the Washington Field Office, negotiated numerous corporate plea, deferred and non-prosecution agreements on behalf of DOJ, and participated in the appointment of, interaction with, and reporting by more than 16 corporate compliance monitors. Mark led an effort to forge closer working relationships with foreign regulators in connection with transnational bribery cases, resulting in coordinated settlements with the Munich Public Prosecutor in Germany in the Siemens prosecutions and coordinated settlements with the U.K.'s Serious Fraud Office in the BAE and Innospec prosecutions, among others. Mark was also responsible for administering DOJ's FCPA Opinion Release Procedure, including issuing the seminal opinion on FCPA transactional diligence and successor liability (Op. Rel. 08-02).

In addition to case-related responsibilities, Mark had significant policy responsibilities, including principal policy responsibilities related to the Organisation for Economic Co-operation and Development (OECD) Anti-bribery Convention. As a member of the U.S. delegation to the OECD Bribery Working Group, Mark served as a lead examiner for the follow-up review of Japan's implementation of the OECD Anti-bribery Convention, played a key role in peer review of the United Kingdom including consultation regarding its Bribery Act of 2010, negotiated the 2009 Anti-Bribery Recommendation, and played a leading role in the drafting and adoption of the OECD's "Good Practice Guidance on Internal Controls, Ethics and Compliance."

During his tenure administering the DOJ's FCPA enforcement program, the DOJ brought more than 50 prosecutions against corporations for violations of the FCPA and related offenses, resulting in more than $1.5 billion in criminal penalties. During that same period, DOJ brought approximately 80 prosecutions against individuals. Among the notable prosecutions were the following: U.S. v. Siemens AG, et al.; U.S. v. Kellogg Brown & Root, LLC and U.S. v. Albert "Jack" Stanley; U.S. v. Congressman William J. Jefferson; U.S. v. BAE Systems plc; U.S. v. Baker Hughes, et al.; U.S. v. Titan Corp.; U.S. v. Statoil ASA; U.S. v. Monsanto; Lucent Technologies, Inc.; U.S. v. Willbros Group, Inc., et al.; U.S. v. Christian Sapsizian, et al.; U.S. v. Viktor Kozeny and Frederick Bourke, Jr.; U.S. v. Gerald and Patricia Green; U.S. v. Innospec, Inc.; and U.S. v. Daimler AG.

Prior to joining the Fraud Section, Mark was senior counsel in the DOJ's Computer Crime and Intellectual Property Section in Washington, D.C., and prior to that served for nearly six years as an assistant U.S. attorney in the U.S. Attorney's Office in the Southern District of New York. During his service with the U.S. Attorney's Office, Mark tried numerous cases to verdict and argued several appeals before the United States Court of Appeals for the Second Circuit. As a federal prosecutor, Mark was a recipient of the Attorney General's Award for Distinguished Service for the "Investigation into Corrupt Payments by Siemens AG," and a recipient of the Assistant Attorney General's Award for "The Safeguarding and Maintenance of Confidence in the American Marketplace." Mark has been recognized by Ethisphere Institute in 2011 as a "Top Gun" among "Attorneys Who Matter," in 2009 as a "Government Star" among "Attorneys Who Matter In Corporate Compliance," and in 2007 and 2008 as one of the "100 Most Influential People in Business Ethics." In 2010 and 2011, Mark was selected as one of the Lawdragon "500 Leading Lawyers in America." Mark is also ranked by Chambers as an International Trade/FCPA expert.

Mark has spoken frequently as a faculty member, panelist and keynote speaker at numerous FCPA, anti-corruption, corporate compliance, securities fraud, money laundering, and white collar crime programs and conferences. He teaches International Criminal Law as a visiting professor at the University of Virginia School of Law and has also been an adjunct lecturer-in-law at Columbia Law School. Mark is member of the Edward Bennett Williams Inn of Court and a member of the Board of Directors of Transparency International-USA.

Anti-Corruption & FCPA
Cybersecurity & Data Protection
Internal Investigations
Securities Litigation
White Collar & Regulatory Defense


J.D., University of Virginia School of Law, 1993

B.A., Yale University, 1989


Hon. Denny Chin, U.S. District Court, Southern District of New York

Bar Admissions

New York
District of Columbia

Related Resources

Feb 17, 2017 | Publications

A Flurry of FCPA Enforcement Actions Marks the End of the Obama Administration

Jan 20, 2017 | Publications

FCPA Enforcement and Anti-Corruption Developments: 2016 Year In Review

Jan 12, 2017 | Videos

Why Anti-Corruption Due Diligence Is Important in M&A Transactions

Nov 01, 2016 | Publications

Embraer SA Pays $205 Million to the SEC and DOJ to Settle FCPA Violations

Nov 29, 2016 | Events

Mark Mendelsohn and Alex Oh to Participate in ACI’s International Conference on FCPA

Oct 13, 2016 | Publications

Recent DOJ and SEC Actions Underscore Regulators’ Pronouncements That “Vigorous Enforcement” of FCPA Violations Remains a “High Priority”

Sep 23, 2016 | Publications

$1.4 Billion Global Settlement Offer to Telia Portends Major Foreign Bribery Prosecution

Sep 15, 2016 | Events

Mark Mendelsohn to Moderate Panel at TI-USA Corporate Forum

Jul 29, 2016 | Publications

Litigation Partners and Counsel Co-Author Article on FCPA Pilot Program

Jul 27, 2016 | News

Outerwall to Be Acquired by Funds Affiliated With Apollo

Jul 27, 2016 | Publications

Analogic and Johnson Controls Settlements Shed Further Light on the Implementation of DOJ’s FCPA Pilot Program

Jul 20, 2016 | Publications

OECD Criticizes Japan for Leniency in Combatting Foreign Bribery

Jul 07, 2016 | Publications

Litigation Partners Author Article on First DOJ Declination Letters Since Launch of Its FCPA Pilot Program

Jun 20, 2016 | Publications

DOJ Publicly Releases First Declination Letters Since Launching Its FCPA Pilot Program

Jun 13, 2016 | News

Paul, Weiss Pro Bono Client Secures Immediate Release From Federal Prison

May 16, 2016 | Events

Mark Mendelsohn and Justin Lerer to Participate in ACI’s Annual New York Conference on FCPA

May 10, 2016 | Publications

FinCEN Issues Sweeping New Requirements on Collection of Beneficial Ownership Information and Customer Due Diligence

May 04, 2016 | News

Kohlberg Acquires Interstate Hotels & Resorts

Apr 06, 2016 | Publications

DOJ Announces a Pilot Program to Encourage Companies to Self-Report FCPA Violations

Apr 05, 2016 | Events

Mark Mendelsohn to Participate in Summit on Compliance Risks for Alternative Investment Industry

Mar 29, 2016 | News

Stantec to Acquire MWH for $795 Million

Mar 29, 2016 | Publications

Novartis AG Settles SEC FCPA Action Involving China Subsidiaries’ Improper Gifts, Travel and Entertainment Payments to Healthcare Providers

Mar 04, 2016 | Publications

The CFPB Enters the Cybersecurity Arena with Its First Enforcement Action

Feb 29, 2016 | Publications

DOJ and SEC Pressure Test Accuracy of Self-Reporting and Cooperation in PTC FCPA Settlement

Mar 02, 2016 | Events

Mark Mendelsohn to Speak at TRACE Forum

Feb 26, 2016 | Publications

VimpelCom Agrees to Landmark $795 Million FCPA Resolution

Feb 25, 2016 | Publications

SEC Settlement Highlights Importance of Third-Party Agent Guidelines

Feb 23, 2016 | Publications

New Federal Guidance on the Cybersecurity Information Sharing Act of 2015: What General Counsel Need to Know

Feb 16, 2016 | Publications

SciClone Pharmaceuticals Settles FCPA Action Over China Business Practices

Feb 01, 2016 | Publications

U.S. District Court Orders Compliance Monitor's Report Unsealed Pursuant to First Amendment Right of Public Access to Judicial Documents

Jan 20, 2016 | Publications

Understanding the Changes to the Iran Sanctions Regime: OFAC Issues Guidance, General Licenses on JCPOA Implementation Day

Oct 28, 2015 | News

Apollo Affiliated Funds Acquire OM Group

Oct 08, 2015 | Publications

SEC FCPA Action Against Bristol-Myers Squibb Highlights Importance of Addressing Red Flags and Compliance Gaps

Oct 02, 2015 | Publications

The SEC’s FCPA Settlement with Hitachi Underscores the Importance of Robust Anti-Corruption Procedures

Jul 24, 2015 | News

Pro Bono Client Wins Unemployment Benefits Appeal

Jul 07, 2015 | News

Paul, Weiss Client Achieves Successful Result in World Bank Sanctions Hearing

Jul 01, 2015 | News

Apollo Affiliated Funds Acquire Protection 1 and ASG Security

May 28, 2015 | Publications

SEC Extends Application of FCPA Accounting Provisions in BHP Billiton Enforcement Action

May 18, 2015 | News

Apollo Affiliated Funds to Acquire Protection 1 and ASG Security
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