FCPA internal investigation for an audit committee
Represented an audit committee in an internal investigation into alleged FCPA violations, including coordination with outside auditors on the committee's remediation and disclosure obligations.
United States (Federal)
Financial Services
Representative Matter
Foreign-bribery evidence against a U.S. public company's subsidiary
Represents a whistleblower with first-hand evidence of bribes paid by a U.S. public company's subsidiary, supporting a potential FCPA enforcement action with exposure exceeding $30 million.
Worked on the defense of a former Gunvor executive charged in the Eastern District of New York in connection with an approximately $22 million PetroEcuador bribery scheme. Gunvor S.A., the Swiss energy trading company, separately pleaded guilty in March 2024 to conspiracy to violate the FCPA and paid a $374.56 million criminal fine as part of a $474.4 million global resolution, admitting it paid intermediaries more than $97 million between 2012 and 2020 to bribe PetroEcuador officials to obtain and retain oil-trading business.
