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The world’s most sophisticated business organizations turn to Covington for anti-corruption advice and investigative counsel.
With roots in the conception of the U.S. Foreign Corrupt Practices Act (FCPA), Covington has been a leading voice on U.S. legislation and policy relating to anti-corruption enforcement and compliance, as well as on new legislation around the world, including the U.K. Bribery Act.
Our global practice has garnered the attention of numerous publications, including Global Investigations Review, Chambers and Legal 500.
As the home to a former U.S. Attorney General, three former heads of the U.S. Department of Justice’s Criminal Division, and numerous other former high-ranking prosecutors, Covington has unmatched expertise in guiding clients safely through this prevailing climate of heightened enforcement.
We are also one of the few firms in the world to have a senior lawyer resident in China who focuses on anti-corruption counseling and investigations.
Across both counseling and investigations, our anti-corruption team is able to provide “24-hour” real-time support to our clients with seamless coordination across the Americas, Europe, Asia, and Africa. Our team has handled matters throughout the world, including in Brazil, China, Eastern Europe, Germany, India, Indonesia, Mexico, the Middle East, Russia, South Korea, and the UK.
We are further distinguished by our ability to translate nuanced legal analysis into practical advice that makes sense to business clients. With more than 35 years of experience advising companies on the toughest compliance questions, conducting internal investigations, and helping to design and implement effective compliance programs, we have the experience and sophistication to guide clients through the prevailing climate of heightened enforcement.
Persuaded the U.S. Securities and Exchange Commission not to pursue enforcement action against a leading manufacturing company following an 18-month investigation of business practices in Europe and Asia.
Representing a high-profile media entity in a U.S. Department of Justice investigation of business practices in the Middle East.
Investigating allegations of fraud, bribery, and collusion in a contract financed by the World Bank and representing the client before the World Bank Integrity Vice Presidency in anticipation of a potential debarment action.
Conducted a large-scale internal investigation of a leading global company’s business practices in China.
Conducted internal investigation relating to customs clearance practices for automotive parts in various Latin American countries.
Represented private equity firm Lindsay Goldberg and PAE as regulatory counsel in six different M&A transactions that have grown PAE to a defense contractor with annual revenue in excess of $2 billion. Our work began in 2011 with Lindsay Goldberg’s acquisition of PAE from Lockheed Martin, and continued through to PAE’s acquisitions of Defense Support Services, CSC’s Applied Technology Division, USIS’s Global Security and Solutions Business, and A-T Solutions and to Lindsay Goldberg’s 2016 sale of PAE to Platinum Equity. Our work in each of these deals has included government contracts, national security, trade controls, and anti-corruption due diligence and advice on transaction structuring, novations, and regulatory approvals.
Represented Hyperdynamics Corporation in an FCPA investigation by the Department of Justice related to its business activities in the Republic of Guinea. The matter was resolved without any charges being brought against the company.
A cross-office team conducting an internal investigation for a major U.S. financial institution of allegations that the bank assisted Argentine nationals evade taxes and launder money. We are also coordinating the bank's global defense strategy, which includes leading strategy meetings with local Argentine defense counsel, and interfacing with key U.S. officials in the U.S. and in Argentina.
Representing 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.
Advising a major petrochemical company regarding its establishment of an integrated compliance program, with particular focus on the areas of U.S. and European trade controls, anti-corruption, and data privacy. Our representation includes assistance with establishing a corporate compliance office, assessing risks in these areas, drafting the necessary policies and procedures tailored to company risks and operations, and implementing the program through training and assessment.
Represented a leading industry coalition in the rulemaking proceeding on the whistleblower provisions of the Dodd-Frank Act.
Advised one of the 300 largest companies in the world on a major DOJ and SEC investigation of potential FCPA violations in India, Latin America and elsewhere.
Advising a multinational chemical manufacturer regarding updates to its integrated compliance program, developing a three-year plan for a comprehensive update, and helping the company assess risk and update its existing policies and procedures in the areas of anti-corruption, third party due diligence and monitoring, and investigations.
Represented a Fortune 15 global company in a long-running and widely publicized FCPA investigation at DOJ and the SEC regarding conduct in Mexico and elsewhere. This case presents cutting-edge issues in the FCPA space relating to jurisdiction and the substantive reach of the statute.
Engaged by a Fortune 500 Life Sciences company to coordinate the investigation of suspected FCPA violations in various countries, including Brazil, and to advise the company’s Internal Audit Department on conducting FCPA audits to ensure compliance.
Representation of a major electronics company concerning all aspects of the European investigation into alleged collusion in TFT-LCD.
Representation of one of the largest providers of telecommunications services in Asia in a DOJ investigation of alleged collusion with respect to termination rates charged to US carriers. The government ultimately closed the investigation and took no action against our client.
Managed anti-corruption due diligence and follow-up with respect to Latin America sales channels for a leading pharmaceutical company, as well as providing general anti-corruption counseling with respect to the company’s Brazilian affiliate.
Representation of a major pharmaceutical company in its response to a Chinese government commercial bribery investigation in China.
Conducting internal investigation on behalf of a multinational pharmaceutical company into whistleblower allegations of corruption at its Chinese subsidiary.
Provided UK Bribery Act advice to a large health insurance company regarding operations in Brazil.
Participated extensively in the consultations leading to the enactment of the 2010 UK Bribery Act.
Representation of a mining company in a Department of Justice investigation concerning anti-corruption (FCPA) matters and related civil RICO litigation.
Advised an oilfield services company on the design and implementation of a corporate responsibility program for its Angolan operations following an FCPA enforcement action.
Represented a U.S. corporation and its principal in connection with a U.S. Department of Justice investigation into alleged FCPA violations involving Russian government officials. The investigation was closed without charges being filed against our clients.
Conducted an internal investigation for a client concerning allegations of bribery involving Russian hospitals and public educational institutions.
Conducted an internal investigation for a manufacturing company relating to sales to Georgia’s Ministry of Agriculture.
Assisted client in negotiating a global settlement of an FCPA investigation, the centerpiece of which concerned bribery involving a major Russian agency.
Conducted an internal investigation for a client concerning allegations of bribery involving Russian customs agencies.
Supported client in conducting anti-corruption due diligence concerning the acquisition of a Russian company.
Represented Deere & Co. in an 18-month investigation relating to its operations in Russia and neighboring countries by the U.S. Securities and Exchange Commission that concluded without enforcement action.
March 9, 2017, Law360
March 2, 2017, Covington Alert
The Fraud Section of the U.S. Department of Justice (“DOJ”) quietly released new guidance last month entitled “Evaluation of Corporate Compliance Programs” (the “Guidance”). While noting that “the Fraud Section does not use any rigid formula to assess the effectiveness of corporate compliance programs,” the eight-page Guidance outlines 11 “Sample Topics and ...
February 3, 2017, Global Investigations Review
Ian Hargreaves and David Lorello are quoted in a Global Investigations Review article regarding Hargreaves’ recent arrival to Covington. According to Hargreaves, the firm’s “pre-eminence in dispute resolution, and its immense strength and global recognition as a market-leader in white-collar crime matters and investigations” fueled his decision.
Lorello says, ...
January 31, 2017
LONDON—Ian Hargreaves has joined Covington as a partner in the firm’s European Dispute Resolution practice resident in London. Mr. Hargreaves’ arrival follows that of litigation partners Craig Pollack, Greg Lascelles, Elaine Whiteford, and Louise Freeman over the past six months.
Mr. Hargreaves advises on major European white collar and related civil and ...
Winter 2017, Covington Alert
Anti-corruption enforcement is at a crossroads. In many respects, global anti-corruption enforcement has never been more active. The U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) in 2016 collected a total of $2.41 billion through FCPA enforcement actions against 27 corporate defendants, including through their share ...
January 27, 2017, Law360
Law360 selected Covington’s International Trade practice as a “Practice Group of the Year,” profiling the team’s involvement in billions of dollars worth of transactions, Foreign Corrupt Practices Act investigations, and sensitive national security trade reviews. “Our practice in general is distinguished by the sheer number of former senior enforcement officials ...
January 3, 2017, Covington Alert
On December 29, 2016, General Cable Corporation (“GCC”), a global manufacturer of wire and cable products, agreed to pay approximately $75.8 million in connection with a non-prosecution agreement with the Department of Justice (“DOJ”) and a cease and desist order with the U.S. Securities and Exchange Commission (“SEC”) to settle allegations that it violated the ...
November 14, 2016, The New Yorker
In a New Yorker article regarding potential conflicts of interest in President-elect Donald Trump’s administration, Arlo Devlin-Brown comments on the importance of avoiding even ‘the appearance of impropriety’ for companies doing business with the Trump Organization.
November 13, 2016, The Wall Street Journal
Arlo Devlin-Brown is quoted by The Wall Street Journal in an article regarding the uncertainty surrounding the types of cases the U.S. Justice Department will pursue during Donald Trump’s presidency. According to Devlin-Brown, “It is only in rare circumstances that a leadership change impacts prosecutions or well-developed investigations already in progress at ...
October 26, 2016, Law360
Lanny Breuer participated at the FCPA Blog Conference and is quoted in a Law360 article regarding concerns raised by a requirement under a pilot Foreign Corrupt Practices Act disclosure program forcing companies to step back from conducting their own investigations. According to Breuer, the FCPA pilot program makes “an extraordinary request” by mandating that ...
October 26, 2016, The Wall Street Journal
Lanny Breuer participated at the FCPA Blog Conference and is quoted in a Wall Street Journal article regarding the FCPA pilot program that will provide discounts to foreign-bribery offenders that disclose and tackle those transgressions and cooperate with the authorities. Breuer said that while it’s too soon to tell if the pilot has had its intended effect, he ...
October 17, 2016, Los Angeles Times
The Los Angeles Times highlights the role of Dan Shallman and Aaron Lewis in helping unravel a bribery case against two brothers who allegedly tried to buy the support of a Huntington Park city council member for higher towing fees. In what Dan Shallman called a “huge vindication,” the court sentenced one of the brothers with probation.
October 7, 2016, Covington Alert
On September 29, 2016, the U.S. Department of Justice (“DOJ”) issued letters of declination to NCH Corporation (“NCH”) and HMT LLC (“HMT”). Both companies are Texas-based “domestic concerns.” The letter to NCH, an industrial supply and maintenance company, relates to an investigation into possible violations of the anti-bribery provisions of the U.S. Foreign ...
September 28, 2016, The FCPA Report
Eric Carlson is quoted in an FCPA Report article regarding China’s data privacy and cybersecurity laws and how they apply to companies doing business in China. Commenting on performing due diligence while avoiding data privacy issues, Carlson says, “For due diligence purposes, it is still safe and appropriate to gather corporate information such as whether a ...
September 20, 2016
WASHINGTON—Global Investigations Review has named the Microsoft warrant access case as the winner of the “Most Important Court Case of the Year.” Covington served as co-counsel to Microsoft and helped secure a landmark win in the U.S. Court of Appeals for the Second Circuit. GIR also ranked Covington among the top 15 investigations practices in the world in its ...
September 19, 2016, Covington Alert
On September 13, 2016, Jun Ping Zhang (“Zhang”), former head of Harris Corporation’s (“Harris”) subsidiary in China, agreed to pay $46,000 to settle allegations by the U.S. Securities and Exchange Commission (“SEC”) that Zhang knowingly authorized and facilitated bribes to Chinese government officials at state-owned hospitals and local health departments and ...
September 12, 2016, Global Arbitration Review
Greg Lascelles and Alex Leitch are quoted in a Global Arbitration Review article regarding Lascelles’ recent arrival to Covington. “I am very excited to join this growing team,” says Lascelles.
According to Leitch, the financial services sector attracts significant client demand and Lascelles’ arrival is a “welcome addition” to the practice.
September 8, 2016, The New York Times
Arlo Devlin-Brown is quoted in a New York Times article regarding the Department of Justice’s decision to end its corruption case against Robert McDonnell. According to Devlin-Brown, “When a new legal standard is articulated by the Supreme Court and there’s a need to potentially retry the case, prosecutors make a very particularized assessment as to whether, No. ...
September 7, 2016, Covington Report
August 30, 2016, Global Investigations Review
Global Investigations Review highlights Covington’s role in helping AB InBev secure a declination notice from the U.S. Department of Justice in an FCPA investigation regarding the company’s business partners in India. The Covington team was led by Steven Fagell, who worked with Lanny Breuer, Jason Criss, and Benjamin Haley on the matter.
August 22, 2016
WASHINGTON—Global Investigations Review has named Covington’s FCPA practice among Washington’s “elite,” the highest tier in its “Washington DC’s FCPA Bar” survey.
In its profile, GIR notes Covington’s “deep bench of high-level former prosecutors,” including former U.S. Attorney General Eric Holder; the last two former heads of the Criminal Division at the ...
July 18, 2016, Covington Alert
On July 11, 2016, Johnson Controls, Inc. (“JCI”) agreed to pay $14.4 million to settle allegations by the U.S. Securities and Exchange Commission that JCI, through its subsidiaries in China, violated the books and records and internal controls provisions of the U.S. Foreign Corrupt Practices Act. The SEC alleged that, from 2007 to 2013, nearly all of the ...
June 13, 2016, Covington Alert
On June 7, 2016, the Securities and Exchange Commission (“SEC”) announced a non-prosecution agreement (“NPA”) with Akamai, Inc., an internet cloud services company, in connection with an investigation of possible violations of the books and records and internal accounting controls provisions of the US Foreign Corrupt Practices Act (“FCPA”) based on payments by ...
On June 7, 2016, the Securities and Exchange Commission (“SEC”) announced a non-prosecution agreement (“NPA”) with Nortek, Inc., a manufacturer of construction and remodeling products, in connection with an investigation into possible violations of the books and records and internal accounting controls provisions of the US Foreign Corrupt Practices Act (“FCPA”) ...
June 3, 2016
NEW YORK—Covington advised the underwriters in connection with Repligen’s $115 million debt offering. The senior convertible notes due in 2021 were placed at 2.125 percent.
Repligen is a bioprocessing company focused on the manufacture of Protein A ligands used by life science companies to purify biologic drugs such as monoclonal antibodies, recombinant ...
May 26, 2016, The Wall Street Journal
David Lorello is quoted in a Wall Street Journal article regarding a recent call to review the UK Serious Fraud Office’s (SFO) funding model after increased scrutiny of the SFO’s governance structure. According to Lorello, “The blockbuster funding has been a matter of significant public attention for some years now." He continues, “As with many government ...
May 6, 2016, Insight
April 21, 2016, Covington Alert
On April 5, 2016, the United States Department of Justice (“DOJ”), through the Criminal Division’s Fraud Section, announced a one-year Foreign Corrupt Practices Act (“FCPA”) enforcement pilot program (the “Pilot Program”) intended to motivate companies to voluntarily disclose FCPA-related misconduct and increase transparency around the Fraud Section’s approach ...
April 6, 2016, The Recorder
Dan Shallman is quoted in this article exploring a DOJ pilot program that could reduce criminal penalties for companies that self-report FCPA violations. According to Shallman, the voluntary disclosure would likely appeal to large companies that face significant FCPA exposure. “It's trickier for cases where the exposure is smaller and less clear," he says.
April 4, 2016
SAN FRANCISCO AND NEW YORK — Latinvex has again selected Covington partners Tammy Albarrán and Nicole Duclos to its annual list of the “Top 100 Female Lawyers” specializing in Latin America among international law firms.
Latinvex chose attorneys from 57 law firms and ten practice areas. The criteria for selection included a combination of factors, including ...
April 2016, Covington Alert
On April 7, 2016, Las Vegas Sands Corp. (“LVSC”) agreed to pay $9 million to settle allegations by the Securities and Exchange Commission (“SEC”) that LVSC, through its subsidiaries in China and Macao, violated the US Foreign Corrupt Practices Act (“FCPA”). The settlement resolves allegations that, from 2006 through at least 2011, LVSC and its subsidiaries ...
On April 18, 2016, the Chinese government released a judicial interpretation that clarifies certain aspects of the PRC Criminal Law with regard to bribery and corruption. The Interpretation provides additional clarity in understanding the amendments to the Criminal Law that took effect last year, most notably by (1) expanding the definition of bribes to include ...
March 25, 2016, Covington Alert
On March 23, 2016, Novartis AG (“Novartis”) agreed to pay $25 million to settle civil charges with the Securities and Exchange Commission (“SEC”) alleging that it violated the Foreign Corrupt Practices Act (the “FCPA”) by paying bribes to healthcare professionals (“HCPs”) in China from 2009 to 2013 to increase sales. Employees and managers of its two ...
March 2016, Covington Alert
On March 1, 2016, the Securities and Exchange Commission announced an agreement with Qualcomm Incorporated to settle charges that it violated the Foreign Corrupt Practices Act by hiring relatives of Chinese government officials to gain business advantages in the Chinese telecommunications market. The SEC also alleged that Qualcomm provided gifts, travels, and ...
February 29, 2016, Covington Alert
February 21, 2016, Covington Alert
February 9, 2016, Covington Alert
Winter 2016, Covington Advisory
December 11, 2015, Covington Alert
October 19, 2015, The Wall Street Journal
Covington’s role in helping Hyperdynamics navigate an FCPA investigation is highlighted in this Wall Street Journal “Risk & Compliance Journal” story. Nancy Kestenbaum said, “It was essential for the company’s survival that it resolve the investigations as quickly as possible.” She also commented on the company’s cooperation throughout. “Recognizing that a ...
October 9, 2015, Covington Alert
September 14, 2015
WASHINGTON, DC, September 14, 2015 - The National Law Journal has named Phyllis Jones and Daniel Suleiman among its “D.C. Rising Stars.” The list recognizes Washington, D.C.’s “40 most promising lawyers age 40 and under.”
Ms. Jones focuses on complex legal issues facing clients in the pharmaceutical and healthcare industries. Her wide-ranging litigation ...
September 2015, Covington Alert
August 2015, JUVE
Quoting Adem Koyuncu on anti-corruption issues in the pharma sector.
July 29, 2015, Covington Alert
May 27, 2015, Covington Alert
May 21, 2015, Covington E-Alert
April 22, 2015, Covington E-Alert
March 2015, Covington E-Alert
Winter 2015, Covington Advisory
January 2015, Corporate Counsel
December 18, 2014, Covington E-Alert
December 17, 2014, Covington E-Alert
December 1, 2014, Covington E-Alert
November 6, 2014, Covington E-Alert
October 16, 2014, Life Sciences Essentials Series Webinar
October 9, 2014, Global Investigations Review
October 9, 2014, Global Competition Review
Q3: 2014, Ethisphere Executive Briefing, Volume 1
August 5, 2014
WASHINGTON, DC, August 5, 2014 — Covington & Burling’s Lanny Breuer, a partner and vice chairman of the firm, has been named to the National Law Journal’s inaugural list of 50 Governance Risk & Compliance Trailblazers & Pioneers. The list recognizes people who have “moved the needle” in the changing ways that law firms conduct business towards governance, risk ...
March 3, 2014, Covington E-Alert
February 3, 2014, Law360
January 27, 2014, Law360
January 2014, Covington E-Alert
January 2014, Covington Advisory
December 2013, Covington E-Alert
November 2013, PLC Guide to Corporate Crime, Fraud and Investigations
July 29, 2013, Covington Advisory
June 24, 2013
WASHINGTON, DC, June 24, 2013 — The National Law Journal named Covington & Burling today as the winner of its Washington Litigation Department of the Year contest in the white collar defense practice category.
“We are honored that the National Law Journal has recognized the many strengths of Covington’s white collar and investigations practice,” said Timothy ...
May 15, 2013, The Global Legal Post
April 26, 2013, Covington E-Alert
March 28, 2013
WASHINGTON, DC, March 28, 2013 — Lanny A. Breuer, most recently the Assistant Attorney General for the Criminal Division at the U.S. Department of Justice, is returning to Covington & Burling as Vice Chair of the firm.
Mr. Breuer’s practice will encompass a wide range of civil and criminal litigation matters, as well as governmental and internal investigations. ...
February 2013, Covington Advisory
November 16, 2012, Law360
November 2012, Covington Advisory
October 19, 2012, Covington E-Alert
October 16, 2012, Covington E-Alert
October 1, 2012
WASHINGTON, DC, October 1, 2012 — Covington & Burling is pleased to announce that it has elected 15 new lawyers to its partnership.
This group is comprised of diverse and talented individuals from five offices who have made their mark at the firm through exceptional work and the highest standards of client service.
“We’re delighted to welcome these 15 lawyers to ...
July 12, 2012, Covington Advisory
July 5, 2012, Covington E-Alert
July 2012, Covington E-Alert
May/June 2012, Breakbulk
April 25, 2012, Covington E-Alert
April 25, 2012, Anti-Corruption China Summit
April 5, 2012, Covington E-Alert
February 17, 2012, Covington E-Alert
LONDON, 2 February, 2012 —Veteran litigator Casey Cooper is joining Covington & Burling as a partner in London, bolstering its global anti-corruption and white-collar practices. Over the past 15 years, Mr. Cooper has successfully represented clients in fraud and corruption investigations arising in the United States, the EU, Russia, the CIS, Asia, Africa, and ...
February 2012, Covington E-Alert
January 18, 2012, Covington E-Alert
November 15, 2011, EuroWatch
November 3, 2011, Covington E-Alert
October 24, 2011, Covington Advisory
October 17, 2011, Covington E-Alert
October 14, 2011, Covington Advisory
October 10, 2011
WASHINGTON, DC, October 10, 2011 — The head of the UK’s Serious Fraud Office, the agency responsible for enforcing the UK Bribery Act, warned corporations last week that the SFO is actively pursuing cases in which foreign corporations have undercut UK companies through corrupt actions in other countries.
“What we are actively looking for is a case where a ...
July 5, 2011, Covington E-Alert
July 2011, Covington E-Alert
June 10, 2011
WASHINGTON, DC, June 10, 2011 — Covington & Burling LLP received 123 individual mentions and 45 practice mentions in Chambers USA 2011. The guidebook, which ranks lawyers by state and national practice area, is designed to identify the most skilled legal practitioners based on the qualities most valued by clients.
Here are the Covington lawyers and practices ...
April 5, 2011, Covington E-Alert
January 2011, Covington E-Alert
August 5, 2010, Covington & Burling Webinar
July 21, 2010, Covington E-Alert
February 20, 2009, Pharmaceutical Law & Industry Report
December 4, 2008, Covington E-Alert
November 2008, Business Crimes Bulletin
May 3, 2008, Covington E-Alert
WASHINGTON, DC, April 3, 2008 — Covington & Burling LLP has announced the promotion of four new of counsels and five new special counsels in the firm’s five offices. The new of counsels are as follows:
Christopher Denig (Washington) focuses on representing clients in complex federal civil litigation (including class actions), internal corporate ...
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