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Anti-corruption and FCPA

Navigating today’s complex regulatory and enforcement environment requires sophisticated legal advice that spans borders. Our leading global anti-corruption team includes “an all-star cast of attorneys on the D.C. FCPA scene” (Global Investigations Review, Just Anti-Corruption). We can help.

  • Top 10 in Global Investigation Review’s GIR Top 100

  • Top 10 in Global Investigation Review’s GIR Top 100

Client Successes

  • Served as lead U.S. counsel to Airbus in a worldwide (26 countries) investigation conducted jointly by the U.S. DOJ, French PNF, and the UK SFO into alleged corruption in the sale of commercial aircraft and other matters. This matter resulted in a history-making $4 billion resolution with U.S., French and UK regulators, the largest simultaneous global (and also the largest simultaneous FCPA) resolution in history. Paul Hastings is also lead counsel for the company in another significant export control matter in the U.S.

  • Represented a major pharmaceutical company in one of the highest-profile pharmaceutical and life sciences FCPA case before the DOJ and SEC. In July 2020, a resolution was reached whereby our client agreed, without admitting or denying the SEC’s findings, to pay $21.4 million to resolve SEC charges that the company violated the FCPA. This resolution, involving no independent monitor and no compliance obligations whatsoever, represents a complete victory for our client on the compliance front.

  • Representing Embraer in its ongoing anti-corruption monitorship that was imposed as part of the company’s 2016 settlement of FCPA investigations by DOJ and SEC. This representation includes liaison with the independent monitor team and advising the company on the general monitorship process, including continued interactions with DOJ and SEC, as well as assisting the company in its efforts to enhance its anticorruption compliance program and related internal controls.

  • Engaged by Panasonic Avionics Corporation (PAC) as independent monitor and compliance consultant, in connection with the company’s resolution of its FCPA matter with the U.S. Government, which included a $137 million criminal penalty. Paul Hastings has been tasked with assessing PAC’s compliance with the terms of its DPA and evaluating PAC’s anti-corruption compliance program and related controls, in terms of both design and effectiveness, in order to address the risk of recurrence of FCPA-related misconduct.

  • Representing a Fortune 100 global financial services company in an internal and external investigation related to FCPA and money laundering investigations into the company’s activities related to a sovereign Asian development fund and misconduct relating to conduct by a former employee.

  • 2020 Compliance Team of the Year

    Law360
  • Washington, DC’s White Collar Litigation Practice Group of the Year

    National Law Journal, 2020

A Dynamic and Sophisticated Practice

Our deep bench of seasoned professionals, including senior defense lawyers as well as former enforcement attorneys from both the DOJ and SEC, has played key roles in virtually every path breaking FCPA settlement over the last decade.

We advise on all aspects of anti-corruption law—including designing and improving compliance programs, conducting due diligence on M&A targets and intermediaries, leading internal investigations and negotiating with government enforcement authorities, handling post-resolution compliance responsibilities, and navigating the civil litigation that often accompanies anticorruption investigations.

  • Firm of the Year – Regulatory & Compliance (International)

    China Law & Practice, 2020
  • Most Impressive Investigations Practice of the Year

    Global Investigations Review, 2017

Global Reach and Experience

  • With offices around the world, we can support cross-border, multi-jurisdictional investigations and assist our clients in the emerging multi-dimensional enforcement space.

  • We have substantial experience representing both individual and corporate clients before enforcement agencies.

  • Our unparalleled expertise in the anticorruption arena has directly led to numerous government-appointed compliance monitorships for multinational companies.

  • One of the two most active global law firms advising on FCPA settlements since 2008

Industry Recognition

  • Recognized as a 2020 Compliance Team of the Year,

    Law360

  • Ranked among the Top 10 in Global Investigation Review’s GIR Top 100

  • Honored as Washington, DC’s White Collar Litigation Practice Group of the Year, National Law Journal, 2020

  • Recognized as the Firm of the Year – Regulatory & Compliance (International), China Law & Practice, 2020

  • Named the Most Impressive Investigations Practice of the Year, Global Investigations Review, 2017

  • Partner Robert Luskin was named a 2020 White Collar MVP by

    Law360

  • Partner Shaun Wu was named Regulatory & Compliance Lawyer of the Year 2020 by China Law & Practice

  • Ranked for Nationwide FCPA, Chambers USA

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