Michael H. Huneke is a partner in the Anti-Corruption & Internal Investigations practice group at Hughes Hubbard & Reed. He advises clients in matters involving the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, corporate governance and compliance, World Bank and other international financial institution matters, international trade controls, securities and accounting investigations, and government contracts.

The Legal 500 has recognized Mike as a "voice of reason when it comes to compliance matters."

He performs anti-corruption investigations and due diligence efforts around the globe, including in connection with US Department of Justice, US Securities and Exchange Commission, UK Serious Fraud Office, World Bank and African Development Bank inquiries. This experience includes conducting corporate compliance monitorships and compliance program evaluations. He has assisted US, European and Asian clients in designing, administering and maintaining anti-corruption, integrity compliance and corporate governance programs. Mike's experience also includes US Congress and US inspector general inquiries.

In connection with his anti-corruption work, Mike has traveled extensively, including to Argentina, Bahrain, Brazil, China, Colombia, Czech Republic, Denmark, France, Germany, Ghana, India, Jordan, Lebanon, Malaysia, Mexico, Morocco, Netherlands, Norway, Peru, Qatar, Romania, Russia, Saudi Arabia, Singapore, South Africa, South Korea, Spain, Switzerland, Thailand, Togo, Tunisia, United Arab Emirates and the UK.

Previous Experience

Associate, white-collar group at the Washington, DC, office of an international law firm, 2005 – 2006 and 2007 – 2010
Clerk, the Honorable Henry Coke Morgan Jr., senior US district judge for the Eastern District of Virginia, 2006 – 2007

Recognitions

Recognized in Legal 500 EMEA- France: Compliance as a Recommended Lawyer, 2018 – 2020
Recognized in Washington, DC, Super Lawyers as a Rising Star, 2014 – 2015
2015 Capital Pro Bono Honor Roll, sponsored by the District of Columbia Court of Appeals and the Superior Court of the District of Columbia

Published Treatises

Anti-Corruption Law and Compliance: Guide to the FCPA and Beyond (Bloomberg BNA, 2014) (with Kevin Abikoff and John Wood) (updated 2017)

Other Highlighted Publications

"Is Foreign Bribery Jurisdiction an Element of Economic Sovereignty? (Part III of III),"Compliance & Enforcement, a blog of NYU Law’s Program on Corporate Compliance and Enforcement, May 28, 2020 (with Jan Dunin-Wasowicz)
"Is Foreign Bribery Jurisdiction an Element of Economic Sovereignty? (Part II of III)," Compliance & Enforcement, a blog of NYU Law’s Program on Corporate Compliance and Enforcement, May 21, 2020 (with Jan Dunin-Wasowicz)
"Is Foreign Bribery Jurisdiction an Element of Economic Sovereignty? Thoughts on Recent Policy Guidance from France and the U.S.," Compliance & Enforcement, a blog of NYU Law’s Program on Corporate Compliance and Enforcement, May 15, 2020 (with Jan Dunin-Wasowicz)
Quoted in "Navigating the Coronavirus Crisis for Compliance Professionals: Part 5 – Final Thoughts," FCPA Compliance Report, April 3, 2020
Quoted in "Navigating the Coronavirus Crisis for Compliance Professionals: Part 2 – Specific Tactics," FCPA Compliance Report, March 31, 2020
"There is No COVID-19 Defense to Corruption," The FCPA Blog, March 18, 2020 (with Kevin Abikoff)
"SCOTUS News: Limits on Immunity for Multilateral Development Banks Should Spur Increased Anti-Corruption Efforts," The FCPA Blog, May 28, 2019 (with Ayoka Akinosi)
FCPA Update: Third-Party Risks and Enforcement Actions, The Review of Securities & Commodities Regulation, vol. 51 no. 1 (January 2018) (with Ashley Hodges)
Quoted in "Five Stages of Corruption and Myriad Internal Controls Failures: Compliance Takeaways From the VimpelCom Settlement," The FCPA Report, March 9, 2016
Quoted in "VimpelCom Settlement Highlights US Government’s New Holistic Approach to Anti-Corruption Enforcement," The FCPA Report, Feb. 24, 2016
Quoted in "The Multimillion Dollar Question: When to Self-Report?" Compliance Week, April 28, 2015
"NY Financial Compliance Landscape May Get Treacherous," Law360, April 22, 2015 (with John Wood)
Quoted in "Global Reach of US Enforcement Collides with Domestic Pressure to Charge Individuals," Main Justice, April 8, 2015
Contributor, Lissack & Horlick on Bribery (LexisNexis, 2nd ed.) (Ch. 12, The International Perspective: Lessons from US Authorities' Enforcement of the Foreign Corrupt Practices Act) (with Kevin Abikoff, John Wood and Ed Little)
"How the Proposed Amendments to the Organizational Sentencing Guidelines Will Affect Corporate Compliance and Ethics Programs," 11 Engage vol. 2 (September 2010)
"When Does an ADR Program Give US Authorities FCPA Jurisdiction over a Foreign Issuer?" 4 Int'l Crim. L. Comm. Newsletter 2:10 (May 2010) (with Patrick O. Hunnius)
"U.S. Sentencing Commission Holds Public Hearing on Proposed Amendments to the Organizational Guidelines," The Federalist Society for Law and Public Policy Studies, New Federal Initiatives Project (April 15, 2010)
"International Legal Developments in Review: 2008, International Criminal Law," 43 The Int'l Lawyer 473, 2009 (with Don Shaver and Elizabeth Bingold)

Highlighted Anti-Corruption Lectures

"Abikoff and Huneke on Corruption Enforcement During the Coronavirus Crisis," Compliance Podcast Network, Podcast, April 14, 2020
Quoted in "FCPA Compliance Report – This Week in FCPA (Episode 197) – The Compliance Doesn't Sleep Edition," Podcast, March 20, 2020
"Significant FCPA Trends and Developments: Bolstering Your Compliance Program," The Knowledge Group, webinar, September 23, 2019
"Anti-Bribery and Anti-Corruption Compliance: Trends, Developments and Best Practices in 2019," The Knowledge Group, webinar, July 10, 2019
"Responding to Investigations by the World Bank and Other Multilateral Development Banks," Hughes Hubbard & Reed, webinar, July 3, 2019
Moderator, “Data Compliance: How Industry Has Updated Policies for Data Collection, Transfers, and Retention,” C5’s 3rd Advanced Conference on Anti-Corruption, Zurich, Switzerland, April 3, 2019
"Third-Party Due Diligence Best Practices: Uncovering the Things You Need to Know," The Knowledge Group, webinar, February 26, 2019
“East Asian Legal Studies Lunchtime Talk Series: Pursuing a Career in Global Anti-Corruption Law,” Harvard Law School, Cambridge, MA, February 21, 2019
"The 2019 Anti-Bribery Landscape: Trends, Developments and Updates," The Knowledge Group, webinar, January 8, 2019
"How DPAs are Affecting Companies' Compliance Function and Compliance Initiatives," C5's 6th Conference on Anti-Corruption, Paris, France, October 16, 2018
“Corruption Scandals: Practitioner-led Case Study," UC Berkeley Law Compliance Academy, Paris, France, July 25, 2018
"US & EU: Conducting and Evaluating Complex Anti-Corruption Investigations with FCPA and Bribery Act," The Knowledge Group, webinar, May 2, 2018
“White Collar Enforcement in 2018: Navigating Recent Changes and Clearing Uncertainties,” The Knowledge Group, webinar, March 1, 2018
“Managing and Mitigating Third-Party Fraud and Corruption Risks: Your Guide for 2017 and Beyond,” The Knowledge Group, webinar, December 1, 2017
"FCPA Enforcement Actions: Highlighting the Importance of Implementing and Monitoring Effective Compliance Programs," The Knowledge Group, webinar, September 18, 2017
"Anti-Corruption Compliance: Trends and Developments in 2017," The Knowledge Group, webinar, August 21, 2017
“Trends and Developments in International Anti-Corruption Enforcement,” Clear Law Institute, webinar, June 29, 2017
"The A-Z's of Anti-Corruption Compliance: What You Need to Know in 2016 and Beyond," The Knowledge Group, webinar, Feb. 16, 2016
"Mitigate Potential Whistleblower Violations Amidst Increased SEC Investigations," The Knowledge Group, webinar Dec. 10, 2015
"Anti-Corruption Outlook for 2016: China, Brazil, the UK and Other Enforcement Hot-Spots," Bloomberg BNA, webinar Dec. 2, 2015
"Best Trends and Practices in Responding to Corporate Whistleblower Reports Explored!" The Knowledge Group, webinar panel discussion, May 1, 2015
"The US Foreign Corrupt Practices Act (FCPA) and International Anti-Bribery Compliance," (part of the US State Department International Visitor Leadership Program’s Regional Program on "Transparency and Accountability," administered by the Meridian International Center, Washington, DC, Feb. 26, 2015)
"Compliance Programs for Government Contractors in 2015 Explored," The Knowledge Group, webinar Feb. 5, 2015
"The World Bank's Expectations and Debarment Powers," C-5 Southern Africa Anti-Corruption Summit 2014, Johannesburg, South Africa, Nov. 18, 2014
"Global Anti-Corruption Compliance and Enforcement: Strategies for Managing the Risks Posed by Third Parties, Business Combinations, and Allegations or Evidence of Misconduct," Bloomberg BNA, webinar, Oct. 29, 2014
"Minimizing Third Party Risks: How to Apply the Right Level of Due Diligence When Monitoring Your Agents, Distributors, Brokers, and CROs," American Conference Institute's 7th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, New York, May 14, 2013
"Negotiating, Drafting and Executing Robust Contracts with Third Parties to Protect your Organisation from Corruption and Bribery Risks," C-5 Second Forum on Anti-Corruption Southern Africa, Cape Town, South Africa, Sept. 18 – 19, 2012)
"Anti-Corruption Risk Assessments & Third-Party Due Diligence," on behalf of Kevin Abikoff (GCM Parker, 2nd Annual Business Ethics Anti-Corruption & Fraud Prevention Strategies in CEE, SEE & CIS, Prague, Czech Republic, March 24, 2011)

Court Admissions

United States Court of Appeals for the Fourth Circuit
United States District Courts for the District of Columbia, Eastern District of Virginia, and Western District of Virginia
District of Columbia Court of Appeals
Supreme Court of Virginia

Highlighted Matters

Current representation of world-leading aerospace and defense company in connection with anti-corruption reviews, risk assessments, and related investigations
Current representation of multinational "supermajor" oil and gas company in connection with a worldwide risk assessment and compliance audit, in coordination with a compliance monitor
Representation of French multinational CAC 40 industrial manufacturing company in negotiated resolution of World Bank investigation and in successful completion of World Bank monitorship and settlement obligations
Current representation of a multinational company regarding African Development Bank sanctions matters
Current representation of a large Chinese state-owned enterprise regarding multilateral development bank sanctions matters
Representation of Norwegian consulting company in contested proceedings before the World Bank's Sanctions Board
Representation of Indian company in connection with World Bank audit and inspection of multiple projects
Conducted a comprehensive compliance review for a leading US government contractor
Representation of a client in parallel criminal and civil export controls investigations by the US Department of Justice and the US Department of Commerce, Bureau of Industry & Security
Organization and execution of an internal investigation at a Fortune 10 energy company regarding a whistleblower’s health, safety, and environmental allegations, and presenting the investigation’s results and recommendations to senior management
Conducted risk-based FCPA compliance review for a multi-national corporation with extensive overseas operations
Conducted FCPA training for in-house personnel
Advising clients on appropriate compliance, due diligence, and contractual safeguards for various international transactions
Represented a former cabinet official regarding several inquiries into events during his tenure and related civil litigation
Represented Americans and their families taken hostage by the Islamic Republic of Iran in November 1979 in civil litigation under the Foreign Sovereign Immunities Act
Represented a defendant charged with criminal violations of federal campaign finance law
Served as lead counsel for plea and sentencing hearings in the US District Court for the Eastern District of Virginia in a criminal case involving false bank records
Represented a defendant who provided substantial assistance to the United States in the prosecutions of a then-sitting US Senator and several state legislators
Represented an attorney in disciplinary proceedings relating to his use of evidence in a federal agency proceeding