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.