Anti-Corruption and FCPA

Businesses around the world are facing increasingly aggressive anti-corruption investigations and enforcement. When a whistleblower complaint, government inquiry, or internal audit surfaces an issue, those caught in the crosshairs can suffer major legal, economic, and reputational harm.

At Jenner & Block, we help businesses around the world address FCPA and Bribery Act concerns with proven strategies. We are a global practice with in-depth experience defending FCPA and Bribery Act claims and helping organizations take a proactive stance to compliance and anti-corruption. We provide internal investigations experience, guidance in government negotiations, training, compliance counseling, training, and compliance counseling.

Uncovering the Facts in Internal Investigations

As one of the leading FCPA and Bribery Act practices, our approach to anti-corruption and anti-bribery investigations helps major national and multinational clients get to the bottom of the facts and emerge stronger. Our scalable teams avoid business interruption with processes designed to withstand strict regulatory scrutiny. Our seasoned judgment helps clients assess the situation and make informed decisions, especially if weighing the potential benefits and risks of voluntary disclosure.

An Experienced Advocate in Enforcement Actions

For clients facing the possibility of an enforcement action, our long-standing experience in negotiating and resolving matters with DOJ, the SEC, the UK Serious Fraud Office and Financial Conduct Authority, and other enforcement bodies informs every stage of their interactions, from the initial investigation to the final settlement. Drawing on our deep understanding of FCPA and Bribery Act enforcement trends and a regulator's perspective, we advocate to reach the best possible outcome and limit reputational damage.

Training and Compliance Program Support

In today’s heightened compliance landscape, companies need a solid compliance program. Companies of all sizes and across sectors, from defense, to finance, oil and gas, media, and retail trust our tailored programs to develop the right controls for their goals and risk profile. We conduct annual risk assessments, update clients’ corruption risk profiles, and enhance their controls through regular policy revisions. Our annual Anti-Corruption Enforcement Year in Review is a valued resource on enforcement and economic developments affecting diverse industries. Our team also develops and delivers effective training programs, devises monitoring protocols to test the effectiveness of compliance efforts, and works with clients on reporting strategies that improve senior leadership’s visibility into potential legal risks.

Transactional Due Diligence Insights

FCPA and Bribery Act compliance plays a key role in any merger or acquisition due diligence process, as well as post-transaction integration. Buyers and sellers rely on our counsel to understand the important compliance and historical issues that could affect the deal. We also help buyers gain a comprehensive picture of target companies to inform valuation and facilitate integration and remediation plans.

  • Conducted an internal investigation for a multinational defense industry company regarding entertainment of foreign officials and represented company in disclosures to State Department, DOJ and SEC.
  • Advised a Swiss-based global automation company in regard to allegations of bribery and corruption and the use of intermediaries, responding to the UK, US, and Swiss authorities.
  • Conducted internal investigations for multinational corporation into potential corruption problems in multiple jurisdictions including Sub-Saharan Africa and Latin America and advised on remediation.
  • Conducted internal investigation into alleged violations of the UK Bribery Act for US manufacturer with global distribution network, and conduct global anticorruption compliance risk post-investigation. Designed a comprehensive anticorruption compliance program to match the company’s risk profile and trained global legal, compliance, finance, and audit team on strategies to mitigate corruption risks.
  • Represented a former CEO of publicly-traded financial services company in an FCPA investigation involving the company’s operations in Mexico.
  • Led global FCPA compliance risk assessment in 25 countries throughout South America, Asia and Europe and worked with Chief Compliance Officer to revamp global anticorruption compliance program.
  • Conducted onsite anti-corruption compliance audits and risks assessments in Africa and the Middle East for Fortune 50 company in conjunction with in-house Audit and Risk Assurance teams.
  • Advised international mining company concerning foreign mining company acquisitions and devised and supervised the client’s due diligence efforts related to the proposed acquisitions.

Experience

  • Conducted an internal investigation for a multinational defense industry company regarding entertainment of foreign officials and represented company in disclosures to State Department, DOJ and SEC.
  • Advised a Swiss-based global automation company in regard to allegations of bribery and corruption and the use of intermediaries, responding to the UK, US, and Swiss authorities.
  • Conducted internal investigations for multinational corporation into potential corruption problems in multiple jurisdictions including Sub-Saharan Africa and Latin America and advised on remediation.
  • Conducted internal investigation into alleged violations of the UK Bribery Act for US manufacturer with global distribution network, and conduct global anticorruption compliance risk post-investigation. Designed a comprehensive anticorruption compliance program to match the company’s risk profile and trained global legal, compliance, finance, and audit team on strategies to mitigate corruption risks.
  • Represented a former CEO of publicly-traded financial services company in an FCPA investigation involving the company’s operations in Mexico.
  • Led global FCPA compliance risk assessment in 25 countries throughout South America, Asia and Europe and worked with Chief Compliance Officer to revamp global anticorruption compliance program.
  • Conducted onsite anti-corruption compliance audits and risks assessments in Africa and the Middle East for Fortune 50 company in conjunction with in-house Audit and Risk Assurance teams.
  • Advised international mining company concerning foreign mining company acquisitions and devised and supervised the client’s due diligence efforts related to the proposed acquisitions.
Anti-Corruption and FCPA

Businesses around the world are facing increasingly aggressive anti-corruption investigations and enforcement. When a whistleblower complaint, government inquiry, or internal audit surfaces an issue, those caught in the crosshairs can suffer major legal, economic, and reputational harm.

At Jenner & Block, we help businesses around the world address FCPA and Bribery Act concerns with proven strategies. We are a global practice with in-depth experience defending FCPA and Bribery Act claims and helping organizations take a proactive stance to compliance and anti-corruption. We provide internal investigations experience, guidance in government negotiations, training, compliance counseling, training, and compliance counseling.

Uncovering the Facts in Internal Investigations

As one of the leading FCPA and Bribery Act practices, our approach to anti-corruption and anti-bribery investigations helps major national and multinational clients get to the bottom of the facts and emerge stronger. Our scalable teams avoid business interruption with processes designed to withstand strict regulatory scrutiny. Our seasoned judgment helps clients assess the situation and make informed decisions, especially if weighing the potential benefits and risks of voluntary disclosure.

An Experienced Advocate in Enforcement Actions

For clients facing the possibility of an enforcement action, our long-standing experience in negotiating and resolving matters with DOJ, the SEC, the UK Serious Fraud Office and Financial Conduct Authority, and other enforcement bodies informs every stage of their interactions, from the initial investigation to the final settlement. Drawing on our deep understanding of FCPA and Bribery Act enforcement trends and a regulator's perspective, we advocate to reach the best possible outcome and limit reputational damage.

Training and Compliance Program Support

In today’s heightened compliance landscape, companies need a solid compliance program. Companies of all sizes and across sectors, from defense, to finance, oil and gas, media, and retail trust our tailored programs to develop the right controls for their goals and risk profile. We conduct annual risk assessments, update clients’ corruption risk profiles, and enhance their controls through regular policy revisions. Our annual Anti-Corruption Enforcement Year in Review is a valued resource on enforcement and economic developments affecting diverse industries. Our team also develops and delivers effective training programs, devises monitoring protocols to test the effectiveness of compliance efforts, and works with clients on reporting strategies that improve senior leadership’s visibility into potential legal risks.

Transactional Due Diligence Insights

FCPA and Bribery Act compliance plays a key role in any merger or acquisition due diligence process, as well as post-transaction integration. Buyers and sellers rely on our counsel to understand the important compliance and historical issues that could affect the deal. We also help buyers gain a comprehensive picture of target companies to inform valuation and facilitate integration and remediation plans.

  • Conducted an internal investigation for a multinational defense industry company regarding entertainment of foreign officials and represented company in disclosures to State Department, DOJ and SEC.
  • Advised a Swiss-based global automation company in regard to allegations of bribery and corruption and the use of intermediaries, responding to the UK, US, and Swiss authorities.
  • Conducted internal investigations for multinational corporation into potential corruption problems in multiple jurisdictions including Sub-Saharan Africa and Latin America and advised on remediation.
  • Conducted internal investigation into alleged violations of the UK Bribery Act for US manufacturer with global distribution network, and conduct global anticorruption compliance risk post-investigation. Designed a comprehensive anticorruption compliance program to match the company’s risk profile and trained global legal, compliance, finance, and audit team on strategies to mitigate corruption risks.
  • Represented a former CEO of publicly-traded financial services company in an FCPA investigation involving the company’s operations in Mexico.
  • Led global FCPA compliance risk assessment in 25 countries throughout South America, Asia and Europe and worked with Chief Compliance Officer to revamp global anticorruption compliance program.
  • Conducted onsite anti-corruption compliance audits and risks assessments in Africa and the Middle East for Fortune 50 company in conjunction with in-house Audit and Risk Assurance teams.
  • Advised international mining company concerning foreign mining company acquisitions and devised and supervised the client’s due diligence efforts related to the proposed acquisitions.

Experience

  • Conducted an internal investigation for a multinational defense industry company regarding entertainment of foreign officials and represented company in disclosures to State Department, DOJ and SEC.
  • Advised a Swiss-based global automation company in regard to allegations of bribery and corruption and the use of intermediaries, responding to the UK, US, and Swiss authorities.
  • Conducted internal investigations for multinational corporation into potential corruption problems in multiple jurisdictions including Sub-Saharan Africa and Latin America and advised on remediation.
  • Conducted internal investigation into alleged violations of the UK Bribery Act for US manufacturer with global distribution network, and conduct global anticorruption compliance risk post-investigation. Designed a comprehensive anticorruption compliance program to match the company’s risk profile and trained global legal, compliance, finance, and audit team on strategies to mitigate corruption risks.
  • Represented a former CEO of publicly-traded financial services company in an FCPA investigation involving the company’s operations in Mexico.
  • Led global FCPA compliance risk assessment in 25 countries throughout South America, Asia and Europe and worked with Chief Compliance Officer to revamp global anticorruption compliance program.
  • Conducted onsite anti-corruption compliance audits and risks assessments in Africa and the Middle East for Fortune 50 company in conjunction with in-house Audit and Risk Assurance teams.
  • Advised international mining company concerning foreign mining company acquisitions and devised and supervised the client’s due diligence efforts related to the proposed acquisitions.

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