FCPA and Foreign Bribery

A sample of representative matters includes:

·                     Investigated sensitive payment allegations involving U.S. public companies or their subsidiary operations in many jurisdictions, including Russia, China, Mexico, Italy, Greece, Singapore, Indonesia, Eastern Europe, and the Philippines.  Advised on local bribery laws, books and records violations, tax and disclosure implications.  Defended resulting litigation, including claims to rescind allegedly tainted contracts.

·                     Represented a major accounting firm in FCPA investigation and prosecution alleging bribery of foreign tax authorities.

·                     Represented defense industry executive in parallel DOJ and SEC investigations of Foreign Corrupt Practices Act violations.

·                     Represented multiple companies in voluntary disclosure of Foreign Corrupt Practices Act violations to the DOJ.

·                     Investigated improper customs broker payments in Africa regarding U.S. public company imports.

·                     Investigated allegedly improper payments to Russian customs and other officials regarding Russian infrastructure facilities constructed by a foreign consortium.

·                     Audited FCPA compliance practices of foreign subsidiaries of a U.S. company in Russia, Eastern Europe and China and addressed disclosure issues in the context of an IPO.

·                     Advised U.S. public company on internal investigation into alleged kickbacks to Russian officials.

·                     Investigated alleged U.S. company involvement in the misappropriation of Russian Government funds.

·                     Represented a government witness in FCPA action against HealthSouth executives.