S. Joy Dowdle

Compliance, Investigations, and Monitorships

Advising a global, ex U.S.-based medical device company in the design and implementation of its ABAC compliance program and related financial controls and representing the company in its ongoing FCPA investigation by the DOJ
Advising a leading global media and entertainment company in the enhancement of its compliance program, including the design and execution of its global compliance risk assessment
Advising a bio-pharmaceutical company on the enhancement of its global ABAC compliance program, including leading a review of the Company’s ABAC-related financial controls and resulting enhancements, conducting proactive reviews in markets across Asia, Europe, and Latin America, and assisting the Company in ongoing resolution negotiations of an FCPA matter before the DOJ and SEC
Advising a Fortune 100, multi-national pharmaceutical company in the continued enhancement of its global ABAC compliance program, including conducting proactive reviews and advising on government-facing strategy and core program components including monitoring, investigations, and remediation
Conducted a global assessment of the ABAC compliance program and related financial controls of a Fortune 15 telecommunications, media, and entertainment company and advising the company (including senior management across operating companies and functions) on resulting program and control enhancement
Representing a multi-national pharmaceutical company in the anti-bribery and anti-corruption due diligence and integration efforts associated with a multi-billion dollar transaction
Served as company counsel facilitating an independent compliance monitorship arising from a top-10, global FCPA resolution with the Securities and Exchange Commission and Department of Justice (monitorship concluded without extension)
Designed and implemented an anti-corruption compliance program for a U.S.-based global exploration and development company
Conducted a global risk assessment and designed the global ABAC compliance program for a medical device company

Civil Litigations

Designed and implemented an anti-corruption compliance program for a consortium formed to build and operate a multi-billion-dollar oil and gas pipeline in Latin America
Participated in the corporate monitorship and successful close out of the deferred prosecution agreement of a Fortune 100, multi-national pharmaceutical company relating to alleged FCPA violations
Designed a compliance program and related internal controls for an oil and gas drilling and platform construction company
Conducted a Section 10A investigation on behalf of a multi-national chemical and refining company; resulted in favorable resolution with the auditor
Represented an up-stream oil and gas company in an FCPA investigation by the DOJ and SEC
Conducted an internal FCPA investigation on behalf of the special committee of the board of directors of an up-stream oil and gas company
Conducted an internal investigation on behalf of an up-stream oil and gas company relating to an oilfield death
Represented the chief financial officer of an office services and equipment company in a stock options backdating investigation by the SEC; resulted in favorable settlement
Represented the chief executive officer of a retail company in a Regulation Fair Disclosure investigation by the SEC; resulted in favorable pre-suit settlement
Represented the general counsel of a broker-dealer in an administrative proceeding by the SEC alleging failure to supervise; resulted in dismissal of all claims by the Commission
Participated in the corporate monitorship of a Fortune 50, multi-national corporation arising from resolution of FCPA violations
Represented an international offshore and onshore drilling and oil field services company in state and federal shareholder derivative actions related to DOJ and SEC investigations of alleged FCPA violations; resulted in favorable dismissals affirmed by the Fifth Circuit
Represented an international offshore drilling company in consolidated state and federal shareholder derivative actions related to resolution of DOJ and SEC investigations of alleged FCPA violations; resulted in favorable dismissals
Represented a pharmaceutical company and several of its directors and senior officers in shareholder derivative and class actions arising from DOJ and SEC investigations of alleged Medicaid fraud; resulted in favorable pre-trial settlement
Represented an internet service corporation in state and federal consumer class actions brought by subscribers; resulted in favorable dismissals
Represented a mutual fund company in a shareholder class action alleging misrepresentations in fund prospectus; resulted in a favorable dismissal

Healthcare: Life Sciences
Legal 500
White-Collar Crime & Government Investigations
Chambers USA
Recognized as a Texas Rising Star
Super Lawyers
Top Attorneys – Texas’ Outstanding Young Lawyers
Texas Monthly

“Not A U.S.-Fits-All-Proposition: Four Key Considerations When Building the Compliance Framework to Go Global with Patient Support (Parts I and II),” Co-author
April 2019
“Going, Going, Gone: First Law of the Trump Administration Repeals Regulations Implementing Section 1504 Reporting Requirements for Payments to Governments by Oil, Gas, and Mining Companies,“ Co-author
February 2017
“Teva Pharmaceuticals Announces a Reserve of $520M in View of What Stands to Be the Fourth Largest FCPA Resolution to Date,“ Co-author
November 2016
“They Keep Coming: The SEC Enters a $5.5M Settlement with AstraZeneca PLC Resolving FCPA Allegations,“ Co-author
September 2016
“Take Two—The SEC Adopts Section 1504 Reporting Requirements for Payments to Governments by Oil, Gas, and Mining Companies,“ Co-author
July 2016
“Seal the Deal: Four Steps to Effective FCPA Acquisition Due Diligence & Integration,“ Co-author
May 2016
“It’s Back—True to the Promise of Continued Scrutiny of Life Sciences, the SEC Enters a $25M FCPA Resolution with Novartis,“ Co-author
April 2016
“Your Joint Venture In Fact Can Be Your Problem: Bristol Meyers Squibb Pays $14M to Resolve FCPA Allegations,“ Co-author
October 2015
“Inside Out: The SEC Awards $1 Million Plus to Yet Another Compliance Professional Turned Whistleblower,“ Co-author
May 2015
“Not Finished With You Yet—The U.S. Government Extends its Deferred Prosecution Agreement with Biomet, Inc. Again Underscoring the FCPA Risk in Life Science,“ Co-author
March 2015
“Proactive Thinking About International White Collar Investigations: How to Mitigate Risks and Manage Key Issues, International White Collar Enforcement,
2015
“SEC Sends a $30 Million-Plus Warning to Companies: Beware of Foreign Whistleblower,“ Co-author
September 2014
“Preparing for Shareholder Lawsuits When Dealing with Foreign Corrupt Practices Act Investigations,“ Co-author
August 2013
“Federal Court Vacates the SECs Section 1504 Reporting Requirements for Payments to Government by Oil, Gas, and Mining Companies,“ Co-author
July 2013
“Long-Anticipated Guidance on the Foreign Corrupt Practices Act Released by the Department of Justice and Securities and Exchange Commission,“ Author
November 2012
“Superman and the Selective Waiver Doctrine: The Potential Impact of Waiving Privilege in Government Investigations in Light of Parallel Litigation,“ Author
July 2012
“SEC Approves Final Dodd-Frank Whistleblower Rules,“ Author
May 2011

“Third-Party Relationship Management: Domestic and Global Risks, Due Diligence, Contracting, Monitoring, Auditing, Termination,” Seton Hall Law’s Advanced Healthcare Compliance Certificate Program, Panelist
May 2023
“Life Sciences Sector Considerations for Measuring the Effectiveness of Compliance Programs: Real-World Takeaways for Updating Your Program Amid the Latest DOJ Guidance and Enforcement Posture,“ 18th Annual ACI FCPA & Anti-Corruption for the Life Sciences Industry Conference, Moderator
May 2023

“Building a Compliance Program from the Ground Up,” 20th Annual Pharmaceutical Compliance Congress, Moderator
April 2023
“Navigating Compliance Risks in Clinical Trials,” Moderator
September 2022
“Town Hall on Work-Life ‘Integration’ in the Life Sciences Industries: How We Can Strive to Achieve the Best of Both Worlds in a Hybrid Work Environment,” American Conference Institute’s 9th Annual Summit for Women Leaders in Life Sciences Law, Panelist
July 2022
“Clinical Trials – The Latest on Managing Unique, Evolving Bribery Risk Factors,” American Conference Institute’s 14th Advanced Forum FCPA & Anti-Corruption for the Life Sciences Industry, Panelist
July 2022
“Diverse Voices in Life Sciences,” Moderator
May 2022
“A Look at Commercial and Medical Affairs to Understand Changes to An Organization’s Evolving Compliance Needs,” Informa Connects Pharmaceutical Compliance Congress, Moderator
April 2022
“Leading Strategies for Monitoring, Auditing, and Risk Assessments,” Informa Connects Pharmaceutical Compliance Congress, Panelist
September 2021
“Virtual First — Trends in Monitoring and Interactions,” Informa Connect’s Compliance Congress for Specialty Products, Panelist
June 2021
“The Evolution of Compliance in the Life Sciences Industry – A Discussion with the Chief Compliance Officers of Alexion and Otsuka,” Moderator
June 2021
“The New Realities of Third-Party Due Diligence with Limited Resources: Five Effective Strategies for Vetting Your Business Partners and Their Partners,” ACI’s 23rd Annual New York Forum on the Foreign Corrupt Practices Act, Moderator
June 2021
“An Interview with the Securities & Exchange Commission,” ACI’s 14th Annual Houston Forum on the Foreign Corrupt Practices Act, Moderator
January 2020
“Interacting with HCPs: Big Picture, Strategic Insights for Ethical Business Conduct, Anti-Corruption and Healthcare Compliance,” ACI’s 13th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, Moderator
June 2019
“More Insights into the Monitorship Process Behind the Curtain,” ACI’s 13th Annual Houston Forum on the Foreign Corrupt Practices Act, Panelist
January 2019
“Assessing the Value of ISO 37001 for Your Business – Whether, When and How to Seek and Maintain Certification,” ACI’s 12th Annual Houston Forum on the Foreign Corrupt Practices Act, Panelist
January 2018
“A Journey to the Dark Side of International Business – Leveraging Front Line Experience to Protect Your Organization and Embed Compliance and Ethics,” Society of Corporate Compliance and Ethics, Regional Compliance & Ethics Conference, Dallas, Texas, Presenter
November 2017
“The Foreign Corrupt Practice Act (and World-Wide Anti-Corruption Enforcement),” Seton Hall Law School, U.S. Healthcare Compliance Certification Program, Faculty
June 2017
“A Practical Debate on the Value of ISO 37001 and Other Compliance Certifications: Weighing the Pros and Cons in the Life Sciences Context,” ACI’s 11th Annual Forum on FCPA & Anti-Corruption for the Life Sciences Industry, Panelist
June 2017
“Sponsorship and Congresses: 5 Big Mistakes to Avoid,” ACI’s 11th Annual Forum on FCPA & Anti-Corruption for the Life Sciences Industry, Panelist
June 2017
“DOJ Compliance Program Evaluation Guidance: What is it and What does it mean?,” North Texas Ethics & Compliance Council, Presenter
May 2017
“The Transformative Impact of the SEC’s Whistleblower Program: How and Why Companies Need to Brace Themselves for an Increased Number of Reports and Awards to Protect Their Investors,” ACI’s 11th Annual Houston Forum on the Foreign Corrupt Practices Act, Panelist
January 2017
“4th Oil and Gas Anti-Corruption Compliance Exchange,” Houston, Texas, Panelist
October 2016
“ACI’s Third Party Due Diligence and Monitoring Seminar,” Chicago, IL, Faculty June,
2016
“Dodd-Frank sections 1502 (Conflict Minerals) & 1504 (Government Payment Reporting): Where things stand and What oilfield services companies are doing to prepare,” Institute for Energy Law, Oilfield Services Practice Committee Meeting, Panelist
October 2013
“Corporate Boards: Perspectives on Risk and Compliance Issues,” Ernst & Young Risk & Compliance Seminar, Panelist
May 2013
“Managing Risk in A Global Economy,” Women’s Global Leadership Conference in Energy & Technology, Panelist
October 2012

Anti-Corruption & FCPA

Complex Litigation

Compliance & Regulatory Counseling

Investigations & White Collar Defense

SEC Enforcement Defense & Regulatory Counseling

Securities Litigation

Life Sciences & Healthcare

Life Sciences Investigations & Enforcement

S. Joy DowdleS. JoyDowdle

REPRESENTATIONS

RECOGNITIONS

Legal 500

Chambers USA

Super Lawyers

Texas Monthly

NEWS & THOUGHT LEADERSHIP

PUBLICATIONS

“Not A U.S.-Fits-All-Proposition: Four Key Considerations When Building the Compliance Framework to Go Global with Patient Support (Parts I and II),” Co-author

“Going, Going, Gone: First Law of the Trump Administration Repeals Regulations Implementing Section 1504 Reporting Requirements for Payments to Governments by Oil, Gas, and Mining Companies,“ Co-author

“Teva Pharmaceuticals Announces a Reserve of $520M in View of What Stands to Be the Fourth Largest FCPA Resolution to Date,“ Co-author

“They Keep Coming: The SEC Enters a $5.5M Settlement with AstraZeneca PLC Resolving FCPA Allegations,“ Co-author

“Take Two—The SEC Adopts Section 1504 Reporting Requirements for Payments to Governments by Oil, Gas, and Mining Companies,“ Co-author

“Seal the Deal: Four Steps to Effective FCPA Acquisition Due Diligence & Integration,“ Co-author

“It’s Back—True to the Promise of Continued Scrutiny of Life Sciences, the SEC Enters a $25M FCPA Resolution with Novartis,“ Co-author

“Your Joint Venture In Fact Can Be Your Problem: Bristol Meyers Squibb Pays $14M to Resolve FCPA Allegations,“ Co-author

“Inside Out: The SEC Awards $1 Million Plus to Yet Another Compliance Professional Turned Whistleblower,“ Co-author

“Not Finished With You Yet—The U.S. Government Extends its Deferred Prosecution Agreement with Biomet, Inc. Again Underscoring the FCPA Risk in Life Science,“ Co-author

“Proactive Thinking About International White Collar Investigations: How to Mitigate Risks and Manage Key Issues, International White Collar Enforcement,

“SEC Sends a $30 Million-Plus Warning to Companies: Beware of Foreign Whistleblower,“ Co-author

“Preparing for Shareholder Lawsuits When Dealing with Foreign Corrupt Practices Act Investigations,“ Co-author

“Federal Court Vacates the SECs Section 1504 Reporting Requirements for Payments to Government by Oil, Gas, and Mining Companies,“ Co-author

“Long-Anticipated Guidance on the Foreign Corrupt Practices Act Released by the Department of Justice and Securities and Exchange Commission,“ Author

“Superman and the Selective Waiver Doctrine: The Potential Impact of Waiving Privilege in Government Investigations in Light of Parallel Litigation,“ Author

“SEC Approves Final Dodd-Frank Whistleblower Rules,“ Author

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