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    Home /  Practices /  Litigation /  FCPA & Anti-Corruption

    FCPA & Anti-Corruption

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    Sullivan & Cromwell is a leader in advising clients around the world on issues arising under the U.S. Foreign Corrupt Practices Act (FCPA) and related international laws. Our team includes former federal prosecutors and other lawyers with extensive experience in FCPA and related matters.

    S&C is uniquely positioned to address the geographic and industry-specific challenges inherent in anti-corruption matters. Our integrated network of 13 offices located in financial capitals around the world, diverse language capabilities and multi-disciplinary approach to matters allow our lawyers to collaborate efficiently with clients and regulators across borders and practices. We excel at handling large multi-jurisdictional matters and cross-border investigations.

    S&C has handled some of the most significant FCPA investigations since the law was enacted, including obtaining the first deferred prosecution agreement ever offered by the U.S. Securities and Exchange Commission. The Firm has also resolved multijurisdictional investigations and secured numerous declinations on behalf of prominent international clients.

    S&C’s team routinely assists clients in all aspects of FCPA and anti-corruption matters, including:

    Investigations

    • Conducting robust internal investigations into possible FCPA violations around the world
    • Representing companies and individuals—based both within and outside the United States—in investigations by the Department of Justice and the Securities and Exchange Commission

    Transactions

    • Advising principals, financial advisers and underwriters on FCPA and anti-corruption issues and compliance enhancements in connection with mergers and acquisitions and corporate finance transactions
    • Leading due diligence efforts and vetting relating to FCPA and anti-corruption issues for M&A or other transactions
    • Advising companies in the midst of FCPA investigations on potential corporate transactions, including divestitures or acquisitions
    • Drafting anti-bribery contractual provisions for, among others, M&A, shareholder, supplier and other third-party agreements

    Compliance & Training

    • Conducting reviews of companies’ worldwide anti-bribery compliance
    • Designing and advising on the implementation of compliance policies and programs

    Foreign Corrupt Practices Act Clearinghouse
    S&C and Stanford Law School launched the Foreign Corrupt Practices Act Clearinghouse, a public database that aggregates and curates source documents and provides analytic tools relating to FCPA enforcement.

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    Spotlight

    S&C a Finalist for New York Law Journal ’s ‘Litigation Department of the Year’

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    S&C Named to Global Investigations Review’s GIR 30 List Again

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    S&C Sidebar – A Conversation with Jay Clayton and Tony Lewis

    Read More
    sc_sidebar_clayton_lewis_368x159

    Brendan Cullen and Tony Lewis Collaborate with Latin Lawyer on The Guide to Corporate Compliance, Fifth Edition

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    S&C Lawyers Discuss Major Developments in National Security Enforcement

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    • Experience
    • Rankings and Recognitions
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    • Practice Contacts
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    Experience

    Experience

    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.
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    Rankings and Recognitions

    Rankings and Recognitions

    • S&C a Finalist for New York Law Journal’s ‘Litigation Department of the Year’

      July 7, 2025
    • S&C Named to Global Investigations Review’s GIR 30 List Again

      November 11, 2024
    • S&C Named Finalist for New York Law Journal’s ‘Litigation Department of the Year’

      July 15, 2024
    • GIR 30 Ranks S&C as a Leading Firm for Corporate Investigations Once Again

      November 17, 2023
    • S&C Shortlisted for Chambers USA ‘Criminal Litigation Law Firm of the Year Award’

      May 12, 2023
    • Law360 “Practice Group of the Year”: White Collar

      March 9, 2023
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    News

    News

    • Kamil Shields Discusses DOJ’s Heightened Focus on Individual Accountability for Senior Executives with Bloomberg Law

      January 25, 2024
    • Aisling O’Shea Discusses Corporate Self-Disclosure Decisions with Bloomberg Law

      March 31, 2023
    • Aisling O’Shea Participates in Stanford “Rock Center Short” on Corporate Governance

      March 20, 2023
    • Nic Bourtin and Aisling O’Shea Comment on DOJ’s New Cooperation Policies for Criminal Cases in Agenda

      February 2, 2023
    • S&C Wins Sixth Circuit Appeal for FCA in RICO Suit by GM

      Updated April 17, 2023
    • S&C Advises Tenaris on SEC Settlement

      June 8, 2022
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    Publications, Videos and Podcasts

    Publications, Videos and Podcasts

    • DOJ Resumes FCPA Enforcement

      S&C Memos |  June 11, 2025
    • President Trump Issues Executive Order, ‘Fighting Overcriminalization in Federal Regulations’

      S&C Memos |  May 14, 2025
    • President Trump Issues Executive Order Pausing FCPA Enforcement

      S&C Memos |  February 12, 2025
    • S&C Sidebar – A Conversation with Jay Clayton and Tony Lewis

      Podcasts |  November 8, 2024
    • U.S. Department of Justice Announces Corporate Whistleblower Awards Pilot Program

      S&C Memos |  August 5, 2024
    • Brendan Cullen and Tony Lewis Collaborate with Latin Lawyer on The Guide to Corporate Compliance, Fifth Edition

      Books |  July 10, 2024
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    Practice Contacts

    Practice Contacts

    Nicolas Bourtin Headshot Photo
    Nicolas Bourtin
    New York
    +1-212-558-3920
    Email
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    Laura Kabler Oswell Headshot Photo
    Laura Kabler Oswell
    Palo Alto
    +1-650-461-5600
    Email
    vCard
    Aisling O
    Aisling O'Shea
    Washington, D.C.
    +1-202-956-7500
    Email
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