Robert F. Amaee

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Robert Amaee specialises in white collar criminal defence work, internal investigations and developing anti-corruption and anti-money laundering compliance programs.  He advises clients on serious economic crime matters (fraud, bribery, money laundering and sanction breaches) and in relation to mandatory and contemplated voluntary disclosures to regulators and enforcement authorities.

Before joining Covington, Dr. Amaee served as Head of Anti-Corruption and Head of Proceeds of Crime at the UK Serious Fraud Office, leading the investigation and prosecution of high-profile bribery and money laundering cases.  He led the negotiations that resulted in civil settlements in the cases of Johnson & Johnson, MW Kellogg/KBR and Macmillan Publishers.  He also served as the SFO’s Head of International Assistance working with law enforcement and governmental agencies including the Financial Services Authority, City of London Police, the Crown Prosecution Service, the Ministry of Justice, the U.S. Department of Justice and the U.S. Securities and Exchange Commission.  He represented the SFO on the Attorney General's Working Group tasked with drafting the Prosecutors' guidance to the UK Bribery Act, the UK Foreign Bribery Strategy Board and the Prosecutors’ forum at the OECD.

Dr. Amaee is admitted to practice as a barrister in England and Wales and has defended and prosecuted cases in the UK criminal courts.  He also has practical business experience having worked in business development roles across EMEA for VeriSign Inc. and APC Inc.  Dr. Amaee holds a Ph.D. in medical research and a B.Sc. in life sciences.

Representative Matters

• Internal investigations into allegations of bribery, including those made by whistleblowers.
• Handling of voluntary disclosures to UK government agencies.
• Anti-corruption risk assessments, including for a US pharmaceuticals company looking to expand into new markets and a Japanese manufacturer with a global footprint.
• Advice to non-UK companies, including an Asian conglomerate, on whether their UK operations are likely to create exposure under the UK Bribery Act.
• Advice to companies on the adequacy of their existing anti-bribery policies and controls, in the context of the UK Bribery Act "adequate procedures” defense.
• Advice to companies on the making of community investments and the provision of sponsorship to public officials.
• Advice to an energy company on the reporting obligations that arise pursuant to the UK Proceeds of Crime Act 2002 following an internal investigation.
• Advice to a software company on its obligations under the UK and EU sanctions and trade controls regimes.
• Assistance to an energy company in its efforts to combat fraudsters that had been using the company name, including investigative work and work to disable the fraud.

Previous Experience

• Head of the Anti-Corruption, Proceeds of Crime and International Assistance Units at the Serious Fraud Office, United Kingdom (2009-2011)
• Criminal Barrister at Chambers of Bill Clegg QC (2 Bedford Row) and Chambers of Clive Nicholls QC (3 Raymond Buildings) (2006-2009)
• Europe, Middle East & Africa territory business development roles at VeriSign Inc. (internet sector) and American Power Conversion Inc. (technology sector) (1995-2002)

Honors and Rankings

• Chambers UK, Corporate Crime & Investigations (2013)
• PLC Which Lawyer?, Corporate Crime, England (2012)
• Legal 500 UK, Fraud - Civil (2012)
• Legal 500 UK, Fraud - Corporate Crime (2011)
• Legal 500 UK, Pharmaceuticals and Biotechnology (2011)

Memberships and Affiliations

• Honourable Society of Lincoln’s Inn 
• The General Council of the Bar

Publications and Speeches

• Mr. Amaee was interviewed by Main Justice (October 2012), "Guidance on Self Reporting under the UK Bribery Act"
• Mr. Amaee participated in a roundtable discussion concerning how Bribery-Act compliant UK Plc is (originally published in Law Business Review, October 2011.)
• Mr. Amaee participated in a roundtable interview with New Law Journal (8/12/2011) on "How Bribery Act-compliant is UK Plc? "
• Mr. Amaee participated in an interview with Russia Today (7/1/2011) on "The UK Bribery Act."
• Mr. Amaee was interviewed by TrustLaw (June 2011), looking at the implications of the new UK Bribery Act.

• "Modus Operandi of Commercial Bribery: Detecting Obvious and Non-Obvious Schemes, Questionable “Business Conducts” and Other Behaviours," C5 London Anti-Corruption Conference (6/25/2013)
• "AMLP Annual Anti-Bribery and Corruption Forum," (6/5/2013)
• "What Indian Firms Should Know About U.S. and U.K. Corruption Laws," The New York Times (5/29/2013), Co-Author