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Covington lawyers have a unique command of anti-corruption laws, in part due to our role in helping to draft the Foreign Corrupt Practices Act of 1977 (“FCPA”). Since the enactment of the FCPA, Covington has advised clients in every aspect of anti-corruption, from representing clients in government investigations to designing compliance programs. Covington’s expertise cuts across many of our premier practice areas, including our White Collar, International, Securities, and Tax groups. Many of our lawyers have served in the U.S. Department of Justice, UK Serious Fraud Office, United States Attorney’s Offices, or the SEC and are well-positioned to understand and anticipate the government’s approach to enforcement in this area.
Our experience includes:
- advising clients on the interpretation and application of anti-corruption laws;
- conducting internal investigations;
- representing corporate clients before DOJ and the SEC;
- providing advice on required SEC disclosures under both the Securities Exchange Act and Sarbanes-Oxley;
- conducting company-wide anti-corruption risk assessments and devising tailored anti-corruption compliance programs;
- training senior management and key operating personnel; and
- interpreting and applying the “books and records” and “internal accounting controls” provisions of the FCPA.
Representative Matters
- Internal investigation in several countries for a multinational company involving alleged payments of many different kinds to professionals employed by governmental entities in those countries.
- 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.
- Investigating alleged FCPA violations by overseas personnel of a large manufacturing company and helping the company to frame a report on the results to foreign authorities.
- Preparation of detailed FCPA risk assessment and compliance materials for an international mining company following extensive worldwide interviews with company personnel aimed at identifying FCPA issues.
- Internal investigations on behalf of manufacturing, industrial and pharmaceutical companies into allegations of payments to foreign officials on every continent of the globe.
- 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, pharmaceutical companies, and aerospace companies.
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