Anti-Corruption and Internal Investigations

The group advises both domestic and foreign corporations on Foreign Corrupt Practices Act and other international anti-bribery issues in all corners of the globe — from the Middle East to China, from Germany to Nigeria — and in a wide range of industries. Our attorneys have advised clients from the inside as corporate compliance counsel; served as government decision makers responsible for bringing civil and criminal enforcement actions; represented parties involved in criminal and administrative enforcement actions as well as in connection with congressional investigations; and provided FCPA training to business representatives and government officials. We assist clients in establishing compliance programs tailored to their specific needs, and we strive to provide viable, forward-looking solutions and alternatives in responding to the discovery of potentially questionable conduct. We also defend companies and offer strategic counseling for companies that find themselves involved in governmental inquiries and due-diligence efforts. In addition, we have developed and continually update a first-in-class FCPA Advisory — now spanning more than 100 pages — that includes not only updates and summaries of developments around the world but also strategic considerations in assessing and implementing key issues to be drawn from the material.

Recent matters in this area include the following:

• Representation of a NYSE-traded pharmaceutical company in connection with issues that arise from time to time around the world related to compliance with the Foreign Corrupt Practices Act and related anticorruption laws. Hughes Hubbard’s work has included the provision of advice related to China, South Korea, South Africa, Indonesia, Nigeria, Burundi, Rwanda, Uganda, Congo, Cameroon, and Saudi Arabia
• Advising a NYSE-traded multinational oil company in connection with issues arising from business relationships in Indonesia, Tunisia, Italy, Nigeria, Sao Tome and Principe, and Venezuela, including successful representation before the United States Department of Justice, Nigerian Economic and Financial Crimes Commission, United States Securities and Exchange Commission, and United States congressional investigative committees
• Representation of a NYSE-traded construction company in due diligence activities stretching around the globe including China, various countries in the Middle East, and former Soviet republics
• Representation of a German-based multinational in connection with self-evaluation of activities in Venezuela
• Representation of a French-based construction company in connection with due-diligence activities stemming from a governmental investigation spanning the globe