FCPA & Anti-Corruption

Energy

• Tenaris in resolving multi-year investigations by the Department of Justice and the Securities and Exchange Commission, which concluded in June 2022 when the DOJ closed its investigation without taking any action and the company resolved the matter with the SEC without admitting or denying wrongdoing.
• ENI S.p.A. in two high-profile FCPA investigations related to its oil and gas businesses in Africa, both of which the DOJ closed without taking any enforcement action, and in resolving related SEC investigations.
• The former CEO of SBM Offshore in criminal investigations in the United States, Brazil and the Netherlands related to alleged corruption in Brazil, Angola, Equatorial Guinea and other countries.

• Statoil ASA (now Equinor) in investigations by the SEC, DOJ and U.S. Attorney’s Office for the Southern District of New York of the agencies’ charges that payments made by Statoil violated the FCPA.
• Current and former employees of Rolls-Royce in DOJ and Serious Fraud Office investigations of corruption in the use of intermediaries in Rolls-Royce’s energy business.

Automotive and Aviation

• Dallas Airmotive Inc., an aviation services company, in resolving an FCPA investigation and negotiating a substantially discounted monetary penalty.
• A multinational automotive company in securing declinations in SEC and DOJ investigations.

Mining

• Kinross Gold Corp., a Toronto-based gold mining company, in its favorable settlement with the SEC stemming from an FCPA investigation arising from the company’s activities in West Africa, and in a parallel investigation by the DOJ, which closed its investigation and declined to pursue charges.
• An Australian mining company in a DOJ investigation related to a joint venture.
• A global mining company regarding the design of an FCPA compliance program.

Financial Institutions and Insurance

• Goldman Sachs as lead counsel in reaching coordinated resolutions in multiple criminal and regulatory investigations in jurisdictions around the world relating to an alleged multi-billion dollar money laundering and corruption scheme involving the Malaysia sovereign development company, 1MDB, and senior public officials in Malaysia and the United Arab Emirates, including a deferred prosecution agreement with the DOJ and resolutions with the government of Malaysia, the SEC, Federal Reserve, New York DFS, and regulators in the UK, Hong Kong and Singapore.
• A major non-U.S. financial institution in U.S. authorities’ long-running investigation into hiring practices in Asia.
• A U.S.-headquartered insurance company in conducting an investigation of a potential FCPA violation by the company’s Mexican subsidiary.
• A major U.S. insurance company in connection with a violation of the FCPA by an employee.

Industrial and Manufacturing

• A global engineering and contracting company concerning a corruption investigation in the Middle East.
• The former CEO of the Brazilian subsidiary of an international offshore construction company in connection with criminal investigations in the United States, Brazil and Singapore related to the Brazilian authorities’ “Operation Car Wash.”
• A lawyer formerly employed in the legal department of a U.S. manufacturing company in an FCPA investigation.

Technology and Electronics

• A major engineering and electronics conglomerate in entering into a settlement with the SEC to resolve FCPA charges relating to conduct by a former employee.
• A technology company in conducting an internal investigation and finding that no reporting was required.
• An African e-commerce company in connection with an internal investigation and advising on its compliance program and internal controls.
• The former CEO of a technology company in securing the dismissal with prejudice of all criminal charges in a long-running and closely followed FCPA prosecution.

Healthcare

• A pharmaceutical company in securing a declination from the DOJ in an investigation relating to activities involving an Asian subsidiary.
• Philips in reaching a resolution with the SEC in an FCPA investigation relating to its business in China. While the investigation had also included Philips’s business in Brazil and Bulgaria, those investigations were closed without action. The DOJ closed its parallel investigation.
• Philips in an investigation of allegations that employees made improper payments to officials at government-run healthcare facilities in Poland.