Sullivan & Cromwell is a leader in advising clients around the world on issues arising under the U.S. Foreign Corrupt Practice Act (FCPA) and related international laws. S&C’s team includes former Assistant United States Attorneys and other lawyers with extensive experience in FCPA and related matters.
Given the Firm’s geographic reach and the breadth of its practice, S&C is uniquely positioned to address the geographic and industry-specific challenges inherent in anti-corruption matters. S&C lawyers synthesize data from a variety of jurisdictions to assist clients in implementing robust compliance programs and responding to alleged compliance breaches. The Firm’s integrated network of 13 offices located in financial capitals around the world, along with its diverse language capabilities, allows its team of lawyers to collaborate efficiently with clients and regulators across borders and practices.
The Firm’s history and experience with FCPA matters has involved some of the most significant investigations, 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 a number of major, international clients.
S&C’s team routinely assists clients in all aspects of FCPA and anti-corruption matters, including:
- 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
- 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 have launched the Foreign Corrupt Practices Act Clearinghouse, a public database that aggregates and curates source documents and provides analytic tools relating to enforcement.