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Covington attorneys have a unique command of the Foreign Corrupt Practices Act of 1977 (“FCPA”) due to their early involvement in legislative activities in formulating the FCPA. Since then Covington has been engaged in all aspects of representation relating to the FCPA, from representing clients in government investigations to drafting FCPA compliance programs. Covington’s expertise cuts across many of its premier practice areas, including its International, White Collar, Securities, and Tax Groups. Many of the Groups’ attorneys have served in the Department of Justice, United States Attorneys’ Offices, or the SEC and are well-positioned to understand the government’s approach in this area.
Covington has:
- advised clients on the interpretation and application of the FCPA;
- conducted internal investigations;
- represented numerous corporate clients before DOJ and the SEC, many of whom were then able to settle matters civilly;
- developed reports to boards and senior management;
- advised on required SEC disclosure under both the 1934 Securities Exchange Act and Sarbanes-Oxley;
- advised clients concerning the desirability of voluntary disclosures;
- advised on related tax consequences;
- conducted company-wide FCPA risk assessments and developed tailored FCPA compliance programs;
- trained senior management and key operating personnel; and
- helped clients interpret and apply the “books and records” and “internal accounting controls” provisions of the FCPA.
Representative Matters
- Multi-country internal investigation for a pharmaceutical company involving all manner of payments to physicians, including those for research grants, consultancies, speaker programs, advisory boards, and other standard pharmaceutical industry programs.
- Representation of an executive of KBR, Halliburton’s subsidiary, in a wide-ranging investigation into alleged bribery of Nigerian government officials in connection with the selection of the company to build one of the world’s largest liquefied natural gas projects.
- Assistance in an investigation of violations in Europe and in framing disclosure made to local authorities for a building supplies company.
- Preparation of detailed FCPA risk assessment and compliance materials for a mining company following extensive worldwide interviews with company personnel aimed at identifying FCPA issues.
- Routine advice to business organizations of all types on FCPA issues, including a prominent auction house, a trade association, an oil company, an independent oil refiner, a manager of funds that invests in the developing world, multiple pharmaceutical companies, and several aerospace companies.
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