Foreign Corrupt Practices

Mike Gass, Christine Savage
Diana Lloyd, Jack Cinquegrana, Melissa Tearney


Foreign Corrupt Practices

Clients doing business globally face increased scrutiny and risk under the Foreign Corrupt Practices Act and other anti-corruption statutes.  We help clients reduce and manage these risks through the design and implementation of effective compliance and training programs, and to mitigate the consequences of suspected violations through investigations and remediation.  Click here for additional information on our government enforcement & compliance capabilities.


Below is a partial list of our recent engagements related to foreign corrupt practices.

  • Software Company, in two internal investigations in the Pacific Rim involving allegations of bribery and financial reporting fraud.
  • Medical Device Company, in an internal investigation into allegations that foreign employees made gifts to government customers in China.
  • Fortune 500 Company, in an internal investigation into entertainment expenses provided by sales representatives to government procurement officials.
  • Pharmaceutical Company, to develop compliance program for sales activities in Russia.
  • Biotech Company, to develop and implement policy statement, compliance and training programs for worldwide sales activities.
  • Medical Device Company, to develop a compliance program for North Africa business activity.
  • Telecommunications Company, to develop a compliance program for its businesses in Eastern Europe and India.
  • Fortune 500 Company, to develop a compliance program for third-party agents in developing countries.
  • Technology Company, in an internal investigation of the relationships between its South American subsidiaries and third-party agents relating to the award of major government contracts.
  • Equipment Manufacturer, in an internal investigation regarding allegations that its South American distributors falsified corporate records to reduce import duties, and in a subsequent global compliance audit.

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