Global enforcement of anti-corruption laws like the Foreign Corrupt Practices Act and the UK Bribery Act has grown exponentially over the last decade.

Cleary Gottlieb has extensive experience advising clients in these matters. With our deep bench of former federal prosecutors and SEC attorneys, we are well-versed in representing companies and individuals in investigations conducted by U.S. and other enforcement authorities. There are also complex and often sensitive collateral consequences to anti-corruption investigations, and we regularly assist boards of directors, general counsel, and members of senior management in managing these issues.

Our experience in conducting investigations and compliance reviews in multiple languages, particularly in Spanish and Portuguese, has made us the firm of choice for clients with significant international operations. And our global footprint allows us to provide our clients with a coordinated, multijurisdictional strategy.

In addition to conducting investigations, we regularly help clients conduct global risk assessments and design their anti-corruption compliance programs. We believe that such programs should not only meet (or exceed) best practices but should also be designed with the practical realities of the client’s business in mind. We also assist clients in implementing revisions to policies, compliance manuals and internal controls and procedures; preparing anti-corruption training programs; and conducting acquisition diligence in a variety of industries and regions.

Notable Experiences

Investigation Highlights

  • Brazilian airline GOL Linhas Aereas Inteligentes S.A. in an anti-corruption independent investigation on behalf of its Special Committee of independent directors.

  • A global real estate and asset management company in connection with an internal FCPA investigation, and related DOJ and SEC investigation, involving subsidiaries in Brazil.

  • A multinational consumer products company in a confidential FCPA investigation in Brazil.

  • Petrobras in a large securities class action litigation in the U.S. District Court for the Southern District of New York asserting claims arising from Operation Lava Jato—the largest corruption scandal in Latin American history.

  • Oberthur Technologies in an investigation by the World Bank’s Integrity Vice-Presidency of bribery and collusion by a subcontractor in connection with a World Bank-funded contract to provide identity cards to the Bangladeshi Election Commission, together with related internal investigations.

  • A multinational metals and mining corporation in an investigation of alleged corruption in Latin America.

  • A major financial institution in a global investigation into the activities of Unaoil S.A.M., which was alleged in a series of press reports in 2016 to have been involved in facilitating the payment of bribes in various jurisdictions, and in connection with related investigations by the DOJ and UK Serious Fraud Office.

  • Alfred C. Toepfer International (a subsidiary of ADM) in an FCPA investigation involving alleged bribery in Ukraine, including in its settlement with the DOJ.

  • A food services company in SEC and DOJ investigations of alleged corruption in Brazil.

  • A Southeast Asian oil and gas company in alleged corruption and potential FCPA violations in Southeast Asia and Brazil.

  • A Mexican construction company in connection with an investigation by the CNBV and potential investigation by the SEC of FCPA allegations.

  • A financial institution based in Asia involving potential FCPA and money laundering allegations arising from the 1MDB investigation.

  • A major medical institution concerning potential FCPA violations related to payments to Saudi officials.

  • Saipem S.p.A. in a DOJ FCPA investigation in Italy and Algeria.

  • An executive in a DOJ investigation of alleged corruption involving FIFA.

  • A former senior executive of Avon Products Inc. in a DOJ investigation of alleged corruption in China.

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Compliance Highlights

  • A global corruption risk assessment and anti-corruption compliance program review in 23 countries, including Brazil and Argentina, for a global consumer electronics business, which also involved a global forensic accounting review.

  • A corruption risk assessment for a paper and pulp company involving multiple jurisdictions in Latin America.

  • An assessment of a Brazilian transportation company’s anti-corruption compliance program, and the implementation of enhancements to that program.

  • A corruption risk assessment, including overseeing a forensic review, for the Chinese operations of a major international consumer products company.

  • A review of the anti-corruption compliance program for a global asset manager with over $30 billion in assets under management, conducted in connection with a FCPA investigation of the asset manager.

  • An anti-corruption compliance policy gap analysis for a Fortune 500 communications company.

  • An annual review of anti-corruption compliance policies and annual global training sessions for business, legal and compliance executives for a global alternative asset manager with $250 billion in assets under management.

  • Designing anti-corruption contract provisions and general anti-corruption advice for a major Latin American development bank.

  • Reviewing the anti-corruption compliance program for a major Latin American petroleum company.

  • Reviewing the anti-corruption policy for a major international bank.

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