Anti-Corruption Compliance & Investigations

Helping companies achieve their business objectives amid growing regulatory scrutiny worldwide

Foley Hoag has extensive experience counseling clients on global best practices and compliance with anti-corruption laws, including the U.S. Foreign Corrupt Practices Act, and other benchmark anti-corruption laws and international standards. Our practitioners provide preventative counseling and forward-looking advice, but also represent companies with global operations of all sizes, as well as individuals, in investigations and enforcement actions. We help clients meet their business goals with sensibly designed compliance programs to successfully navigate increasing regulation and coordinated enforcement by regulators around the world.

Foley Hoag lawyers have decades of experience counseling clients in these areas, including:

Representing companies and financial institutions and their boards and executives in complex criminal investigations and related civil proceedings brought by U.S. or foreign regulators.
Conducting confidential internal investigations concerning allegations of corruption, money laundering or other improper activity and advising clients on effective responses.
Assisting clients in assessing compliance risks and developing and implementing compliance policies and practices tailored to their unique business needs.
Providing FCPA and anti-corruption compliance training to companies in a variety of industry sectors.
Advising U.S. and non-U.S. companies regarding anti-corruption due diligence in connection with mergers and acquisitions and other business transactions in the U.S. and abroad.

Our team consists of nationally recognized and ranked lawyers who have a wealth of, and varied, experience in anti-corruption-related matters. Our White Collar and Government Investigations Group includes alumni of the U.S. Department of Justice as well as state law enforcement agencies. Our lawyers have a wealth of highly successful trial experience in federal and state courts across the country. We also regularly partner with a strong global network of respected local legal and investigative resources. In addition, team members have worked in-house at some of the world’s largest companies helping to develop and manage anti-corruption compliance programs and to respond to Government investigations, including assisting in the self-disclosure of potential FCPA violations. Leveraging this practical experience, we work closely with our clients to tailor our approach to clients’ business needs and organizational culture and structure.

Key Contacts

Anthony Mirenda

Partner

Boston

+1.617.832.1220

amirenda@foleyhoag.com

Adam Safwat

Partner

Washington, DC

+1.202.261.7372

asafwat@foleyhoag.com

Related Practices & Industries

As our expertise is wide-ranging, our attorneys also specialize in a number of related areas.

Experience

Company Defense and Internal Investigations

Conducted internal investigations and pursued related civil fraud litigation concerning allegations of corruption involving the procurement subsidiaries of a global oil and gas company.
Conducted internal investigation for a technology company concerning alleged kickbacks provided in violation of the FCPA in the Middle East.
Conducted internal investigation for a diagnostic testing company concerning alleged kickbacks provided in violation of the FCPA in Brazil.
Represented international audit firm in OIG investigation involving cost accounting practices and potential FCPA violations.
Advised U.S. investment funds in connection with allegation of potential FCPA violations in Brazil.
Represented global manufacturer in the defense industry in federal investigation into potential kickbacks involving head of international sales.
Conducted internal investigation for a technology company concerning alleged kickbacks provided in violation of the FCPA in Venezuela.
Advised board of global investor in connection with allegation of potential kickbacks involving fund management and investments in Latin America.
Conducted an internal investigation of alleged kickbacks and gratuities to senior company executives for an international manufacturer, including pursuit of civil RICO and fraud actions against the executives and contractors involved.
Conducted an internal investigation for a global energy company in one of the largest FCPA investigations in U.S. history.*
Conducted in-country FCPA investigations on behalf of global companies in Brazil, China, the UAE, Egypt, Jordan, Lebanon, Turkey, and Kazakhstan.*
Represented a multinational Fortune 100 Insurance Company in connection with an internal FCPA compliance investigation.
Represented a large multinational engineering company in connection with an FCPA internal review.
Represented a Fortune 100 Life Sciences company to coordinate the investigation of suspected FCPA violations in India, Ukraine, China and Brazil, and to advise the company’s Internal Audit Department on conducting FCPA audits to ensure compliance.

Representation of Individuals

Advised the U.S.-based board member of a global high technology company regarding an internal investigation and external reporting of alleged corrupt activities by former executives.
Represented the CEO of major U.S. exporter in an internal and federal investigation of alleged FCPA violations in connection with foreign military procurement processes.
Represented the CEO of a large financial institution in criminal and regulatory investigations concerning anti-money laundering compliance.
Represented multiple corporate executives of a large European pharmaceutical company in connection with a DOJ/SEC FCPA investigation involving activities in Eastern Europe and Africa.
Represented an individual key company employee in an FCPA investigation in Latin America.
Represented former executives of a major South Korean industrial firm an FCPA matter arising in Brazil before U.S. regulators and in related U.S. civil proceedings and an international arbitration.*

Audits, Self-Assessments and Due Diligence

Conducted FCPA due diligence for a large oil and gas company in connection with a proposed acquisition.
Conducted FCPA due diligence for a Fortune 500 information technology company in connection with a proposed acquisition.
Conducted due diligence and provided FCPA counsel for startup related to potential African government customer.
Conducted FCPA due diligence on behalf of a leading contract research organization in connection with the proposed acquisition of a consulting firm.
Conducted FCPA due diligence on behalf of a healthcare technology company in connection with the proposed acquisition of a patient engagement platform provider.

Compliance Program Development and Training

Served as counsel to an independent monitor selected by the Department of Justice and the Securities and Exchange Commission to assess a global financial institution’s international compliance program.
Advised leading anti-corruption non-governmental organization with respect to proposed federal anti-corruption and anti-money laundering legislation and rulemaking.
Advised global consulting firm on assessing corruption risks in the Middle East, South America and elsewhere, and implementing and enhancing its anti-corruption compliance program.
Advised global manufacturers on assessing corruption risks and implementing and enhancing its anti-corruption compliance program.
Provided FCPA and anti-corruption compliance training and advice on implementation and enhancement of anti-corruption compliance programs, to public and private companies, including global oil and gas company subsidiaries, global manufacturers and professional services firms.
Provided anti-corruption advice and compliance training to a major non-profit foundation.
Conducted an SEC-mandated global FCPA compliance review reporting to the SEC.

* Denotes matter handled by Foley Hoag LLP attorney prior to joining the firm