Ayoka Akinosi is an international specialist in Hughes Hubbard’s Washington, D.C. office, where she primarily works with the Anti-Corruption & Internal Investigations practice group. Ayoka has helped clients (i) design, draft, and manage third party anti-corruption risk management programs; (ii) conduct integrity risk and internal controls assessments; and (iii) implement compliance program effectiveness reviews in the U.S. and across Asia, Europe, and Africa. Ayoka has also conducted due diligence reviews of potential FCPA issues in various corporate transactions and conducted complex investigations connected with potential violations of the anti-corruption laws and related international standards. She also provides anti-corruption compliance training and advises on corporate governance matters.
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 and its pilot sanctions framework. She also co-led highly sensitive complex investigations on fraudulent and collusive practices, negotiated settlements on behalf of the bank to secure financial remedies, and conducted integrity risk assessments across the institution’s member countries. Ayoka was a member of the taskforce responsible for developing the bank’s Strategic Framework and Action Plan on the Prevention of Illicit Financial Flows in Africa (2017 - 2021). She also previously served as solicitor in Nigeria and as external consultant at the International Trade Centre (UNCTAD/WTO) in Geneva, Switzerland. Ayoka is a CFA® charterholder.
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
Highlighted Matters
Designed, drafted, and reviewed anti-corruption compliance programs, including third party management processes for multinational companies in the energy, telecommunications, and aerospace sectors
Assessed anti-bribery compliance risks for global business partners in high-risk markets
Assisted on internal investigations and other aspects of administrative sanctions processes of multilateral development banks, including the African Development Bank, Asian Development Bank, and the World Bank
Selected Pro Bono Matters
Assisted on a matter before the Social Security Appeals Council
Assisted on a claim for U.S. Special Immigrant Juveniles Status for the protection of an El Salvador minor
