Ayoka Akinosi is an international specialist in Hughes Hubbard’s Washington, D.C. office. Ayoka works primarily with the Anti-Corruption & Internal Investigations practice group. She has assisted with response strategies to regulatory enforcement actions and with formulating risk mitigation structures. Ayoka has also assessed operational and project risk profiles, and conducted third party due diligence for clients in high-risk markets. She has helped design and develop global investigations and compliance programs including policies, procedures and protocols for multinational clients with operations in Africa, Asia and South America.
Prior to joining Hughes Hubbard, Ayoka worked with the African Development Bank Group in Tunis, Tunisia, where she developed and drafted the integrity due diligence framework for private sector operations. At the African Development Bank Group, she also negotiated settlement agreements, resulting in admissions of sanctionable practices and financial remedies ($48 million), and advised on the bank’s risk exposure. Ayoka also previously served as solicitor in a Nigerian commercial practice, and as external consultant at the International Trade Centre (UNCTAD/WTO) in Geneva, Switzerland. Ayoka has earned the right to use the Chartered Financial Analyst designation.
Recognition
2016–2017 Capital Pro Bono Honor Roll, sponsored by the District of Columbia Court of Appeals and the Superior Court of the District of Columbia
Selected Publications and Lectures
"How to Refit your Company’s Compliance Programme in the Post-Covid 19 Workplace,” Global Investigations Review (April 2020) (article co-authored with Anne Hukkelaas Gaustad)
"Significant FCPA Trends and Developments: Bolstering Your Compliance Program," The Knowledge Group Webcast (September 23, 2019)
"SCOTUS News: Limits on Immunity for Multilateral Development Banks Should Spur Increased Anti-Corruption Efforts," The FCPA Blog (May 28, 2019) (with Michael Huneke)
“General Cable Pays $75 Million to Settle Wide-Ranging Bribery Scheme Based on Agents and Distributors,” The FCPA Report , Vol. 6 No. 1 (Jan. 18, 2017)
“Identifying Risks and Challenges in a FCPA Violation: What You Need to Know,” The Knowledge Group Webcast (May 18, 2016)
“Regional Risk Spotlight: Ayoka Akinosi Discusses the Crackdown on Corruption in Nigeria,” The FCPA Report , Vol. 5 No. 4 (Feb. 24, 2016)
“Asset Recovery and the Department of Justice’s Discretion to Return,” The Global Anticorruption Blog (Aug. 31, 2015)
“Sanctions Systems of Multilateral Banks: Overview and Responses,” The Global Anticorruption Blog (Aug. 7, 2015)
“Institutions, Not Heroes: Lessons from Nigeria’s EFCC,” The Global Anticorruption Blog (Apr. 27, 2015)
Professional Activities
Member, CFA Institute, CFA Society of Washington, D.C.
Highlighted Matters
Ongoing assessment of anti-bribery compliance risks relating to global business partners of two CAC 40 French multinationals
Assisted in designing and reviewing compliance programs, and related risk-based training for multinational companies, including a Chinese state-owned company, a South African company, and a U.S. manufacturer
Assistance in matters relating to administrative sanctions systems, including an Indian company and a South African subsidiary of a multinational company; supported representation involving audits, investigations, review of internal controls, and compliance with conditions of negotiated resolution agreement
Ongoing support for country analysis to mitigate anti-corruption risks in client’s operations in sub Saharan Africa
Selected Pro Bono Matters
Assisted on a matter before the Social Security Appeals Council
Assisting on a claim for U.S. Special Immigrant Juveniles Status for the protection of an El Salvador minor
