O. Ayoka Akinosi is an associate in the Anti-Corruption & Internal Investigations practice group. Her practice focuses on compliance counselling and regulatory enforcement defense in connection with multijurisdictional investigations by state enforcement agencies and multilateral development banks (“MDBs”).
Ayoka advises clients on the design and effectiveness of compliance programs, including by reviewing and developing due diligence mechanisms, drafting compliance policies and procedures, conducing internal controls adequacy assessments, and providing compliance training. She also represents clients undergoing audits and investigations, conducts compliance risk reviews, and counsels on corporate governance matters. Ayoka is a Chartered Financial Analyst (CFA®) charterholder and has also conducted due diligence reviews of potential FCPA issues in various corporate transactions.
Ayoka’s MDB practice builds
from her prior experience with the African Development Bank Group, where she developed
the bank’s integrity due diligence program, conducted complex fraud and
corruption investigations, and negotiated settlement agreements. In addition,
she 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).
"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)
“The HLS Lawyer of the 21st Century: Building a Career Across Borders – Interview Advice for International Students,” Harvard Law School, Cambridge, MA, March 21, 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
Judge, Americas and Caribbean semi-finals of the International Bar Association and the International Criminal Court’s moot court competition (2022)
Member, CFA Institute
Highlighted Matters
Compliance Counselling, Risk Assessments, and Regulatory Enforcement Defense
Representation of one of the world’s largest energy companies regarding FCPA and Sapin II compliance risk reviews in Angola, Brazil, China, Congo-Brazzaville, Geneva, Kenya, Mauritania, Mexico, Myanmar, Nigeria, Philippines, Poland, Russia, Tanzania, Uganda, and Vietnam
Conducted anti-corruption risk assessments across Central Asia and Eastern Europe on behalf of publicly listed telecommunications company
Represented a French-American global energy services company regarding compliance risk reviews in Brazil and provided general anti-corruption advice
Represented a European aerospace and defense corporation regarding M&A due diligence review
Developed, drafted, and advised on the implementation of the third party due diligence program for a multinational telecommunications company
Counseled a Swiss multinational regarding corporate governance matters associated with a publicly listed Nigerian subsidiary
Advised one of the world’s largest independent commodities trading houses regarding local content requirements and assessed adequacy of compliance controls and anti-corruption due diligence in relation to commodity trading party
Counseled global energy company in regarding Nigerian petroleum regulations and local content requirements
Assisted a client in complying with audit requests by the French anti-corruption agency (l'Agence française anticorruption)
Assessed client’s anti-bribery compliance risks for global business partners in high-risk markets
Highlighted Matters
Multilateral Development Bank Practice
Represented the subsidiary of a French public-private partnership in World Bank sanctions proceedings
Represented a French health consulting company in World Bank investigations regarding activities in Albania
Represented a Chinese civil engineering and construction subsidiary of a Fortune Global 500 company in resolving allegations brought by the African Development Bank
Advised a global defense company in resolving regulatory inquiries by the African Development Bank
Assisted a Beijing-registered joint stock company and one of China’s largest construction groups in securing release from sanction imposed by the World Bank
Assisted a Chinese state-owned international engineering company in securing release from the World Bank
Advised a Chinese state-owned construction machinery manufacturer in assessing consistency of its compliance policies with the integrity compliance guidelines of multilateral banks
Defended an executive of a company cooperating with World Bank investigations, resulting in resolution of allegations against the executive
Assisting a Chinese state-owned engineering and construction contractor in securing release from sanction imposed by the World Bank
Assisting in connection with a monitorship imposed by a multilateral development bank
Counseled a multilateral development bank regarding their internal and external investigation manuals and other policies
Highlighted Matters
Highlighted Pro Bono Matters
Represented a client before the U.S. Social Security Appeals Council
Representation of an El Salvador minor regarding a claim for U.S. Special Immigrant Juveniles Status
