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Businesses operating in the international marketplace must address the new reality of Foreign Corrupt Practices Act (FCPA) and international anti-corruption compliance. Enforcement of the FCPA continues to reach unprecedented levels, and the severity of recent FCPA financial penalties and prison sentences is staggering. The U.S. is not alone in its aggressive approach to enforcement of anti-corruption laws. Recent years have seen a proliferation of international anti-corruption conventions and laws, most notably the UK Bribery Act, and the globalization of international anti-corruption investigations and prosecutions.

Attorneys in our FCPA and International Anti-Corruption practice understand this new reality and the challenges that companies, both publicly-traded and privately-held, face in trying to adapt to it. We combine international sophistication with Midwestern sensibility to meet these challenges, offering the full spectrum of FCPA and international anti-corruption services, including:

Compliance Programs
We assess anti-corruption risks and develop, implement and manage continuously improving tailored anti-corruption compliance programs that minimize those risks. We provide ongoing support for anti-corruption compliance programs through monitoring of threats, day-to-day counseling, evaluation, periodic audits and testing, and annual updates of anti-corruption policies, procedures and standards.

Due Diligence
We conduct anti-corruption due diligence on international business partners (e.g., distributors, consultants and other agents), potential employees, M&A targets and JV partners. We also ensure that our clients are protected through contractual provisions, such as anti-corruption representations and warranties and audit rights.

We design anti-corruption compliance training programs and provide anti-corruption compliance training (in-person, online or recorded) to board members, officers, senior executives, employees and third-parties.

Internal Reviews & Investigations
We conduct internal reviews of potential anti-corruption law violations, anti-corruption red flags and whistleblower complaints. When additional information is needed to determine if any anti-corruption law violations have occurred, we perform internal investigations. Throughout the internal review and investigation process, we counsel clients regarding the potential costs and benefits of voluntary disclosure of violations to enforcement authorities. We also represent individuals who are targets or subjects of internal anti-corruption investigations.

Government Investigations & Enforcement Defense
We defend companies and individuals who are subjects or targets of government anti-corruption investigations, enforcement proceedings or prosecutions.

Our FCPA and International Anti-Corruption practice consists of attorneys with extensive experience in international compliance, internal investigations and white collar criminal defense. Our team includes a former United States Attorney, a former Principal Deputy in Charge of the United States Office of Independent Counsel’s Washington, D.C. office, and former Assistant United States Attorneys. As a member of The Interlex Group®, an international network of leading independent law firms, we have ready access to local counsel and investigation infrastructures in countries from which FCPA and international anti-corruption issues often emanate, including Brazil, Russia, India and China. While we have the international reach of larger market firms, we are able to offer significantly lower fees and better cost predictability because of our Midwestern location and commitment to value-based fee arrangements.

Photo of Arthur McMahon, III
Arthur McMahon, III
FCPA & International Anti-Corruption Practice Contact
(513) 357-9607
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Photo of Trent J. Sandifur
Trent J. Sandifur
FCPA & International Anti-Corruption Practice Contact
(317) 713-3443
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