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As more countries ramp up regulation across disciplines, from anti-corruption to trade controls, the challenges of doing business globally grow increasingly complex. With more than 120 former government officials around the world, Covington understands governments and the factors driving increased regulation. Our integrated compliance offering provides “one-stop shopping,” coordinating strategies across regulatory disciplines and accounting for the nuances of particular jurisdictions and agencies. Covington’s top-ranked, multi-disciplinary team gives your business a competitive advantage.
Covington provides rare sophistication across a wide range of regulatory regimes in the United States, Europe, China and beyond. Our capabilities span anti-corruption; anti-money laundering; antitrust and competition; consumer product safety compliance; election and political law; employment, employee benefits and executive compensation; government contracts; international trade controls; import compliance and customs; privacy and data security; public policy and government affairs; and white collar defense and investigations capabilities.
Our team includes a deep bench of lawyers who formerly served in senior roles with a broad spectrum of government bodies, including the U.S. Departments of Justice, Commerce, Treasury, State, Homeland Security and Defense; the Federal Trade Commission; the United Nations; the European Parliament; and the Committee of Permanent Representatives to the European Union. Many of our lawyers have also managed corporate compliance functions in-house, and all of our lawyers appreciate our clients’ need for pragmatic, efficient advice.
Even as regulatory requirements expand, compliance departments are being asked to do more with less. This trend puts a premium on efficient approaches to compliance, with customized programs tailored to the needs of the company that minimize unnecessary procedures and leverage processes in one area to achieve multiple regulatory goals.
We assist with the development, updating, and review of global compliance programs for major multinationals, as well as with due diligence reviews and day-to-day advice on regulatory developments. We move swiftly to protect you in enforcement scenarios—from ‘dawn raids’ to subpoenas to internal whistleblowing. As regulators around the world increasingly target individuals, even requiring criminal pleas, our practical experience is more critical than ever.
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.
Advising a major multi-sector industrial company in developing an integrated compliance program, including assessment of the company’s corporate risks and current compliance function, and the creation and implementation of training regimes, tailored policies and operational procedures to support those policies, and mechanisms to monitor compliance and address any issues that arise. The enhanced compliance program is designed to support a wide variety of business units, including industrial sites, and sales and procurement functions. The project also entails developing policies to address compliance in the company’s third-party collaborations.
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.
Advising a major multinational aerospace company regarding the application of European export controls to its operations at multiple sites across 10 countries.
Advising remanufacturers and refurbishers of consumer products as to FTC and state law regulating their ability to describe products as “new.”
Conducted a post-acquisition trade compliance review for a global pharmaceutical company that included a voluntary disclosure to the U.S. Commerce Department. We also provided related Iran sanctions advice.
A voluntary disclosure to USAID by one of its largest not-for-profits led the agency to suspend the entity for potential false claims and lack of internal controls, resulting in the board of directors forcing the resignation of the entity’s leadership team and hiring our lawyers to resolve the matters. When the agency refused to lift the suspension due to the lack of trustworthy internal controls and the entity was on the brink of shuttering its doors, our lawyers successfully negotiated a grand bargain to transfer nearly all of the programs, assets, and employees to another not-for-profit and settle the False Claims Act (FCA) investigation.
We have helped major contractors navigate the specific Organizational Conflicts of Interest (OCI) rules and requirements imposed by the Centers for Medicare and Medicaid Services (CMS), the Defense Health Agency, and other agencies. When CMS rolled out its new approach to OCIs, including its new standard clause and required forms, we helped a major CMS contractor comment on key aspects of the approach.
In the wake of the failed launch of healthcare.gov, we helped a major health IT company navigate compliance and other issues related to its healthcare.gov contract and efforts to remediate the website and related IT systems.
Organized foreign counsel in 40 foreign countries to determine legal requirements governing U.S. government contractors working in country, to ensure local compliance as to business registrations, visas, employment laws, and taxes. In doing so, developed a template for determining foreign requirements and a network of local counsel to serve as a resource for the contractor.
For a U.K.-based company in the aerospace sector, we drafted a Technology Control Plan taking into account the applicable EU, Member State, and U.S. trade controls.
Conducted a due diligence review of International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), economic sanctions, and anti-boycott compliance in connection with the acquisition of a U.S. defense subcontractor by a foreign buyer.
One of the nation’s largest construction supply companies was investigated for failing to provide the General Services Administration (GSA) with its “best pricing” for materials. Working with the company’s auditors, we were able to resolve the matter for no money based on ambiguities in the Schedule language as applied to the circumstances.
Successfully represented a major defense IT contractor in an audit of two U.S. General Services Administration (GSA) Schedule contracts by the GSA Inspector General (IG), in which the IG initially asserted a claim for the repayment of tens of millions of dollars. The matter was resolved for less than $5,000.
Counseled clients on WTO and NAFTA disputes on a wide range of matters, including sanitary and phytosanitary regulations, anti-dumping and countervailing duties, agricultural subsidies, and intellectual property issues, including the FSC and Byrd WTO disputes against the United States. Our lawyers have argued cases before the WTO and have negotiated solutions related to implementation, compliance, and retaliation in trade disputes.
Represented a major U.S. textile manufacturer and its European parent company in connection with a proposed Section 592 penalty in excess of $500,000, arising from various alleged classification and valuation errors.
We advised an international energy company on a U.S. Treasury Department investigation of transactions with certain U.S.-sanctioned markets, and assisted the company with interactions with the U.S. State Department on sanctions-related policy matters. The Treasury Department closed its investigation without taking any enforcement action against our client.
Represented a Fortune 100 company in a multi-million dollar dispute with the customs authority in a foreign country with respect to the proper valuation of U.S. goods exported to that country.
Represented a major retailer in a criminal investigation and Section 592 penalty proceeding with respect to the posting of antidumping cash deposits.
Assisted financial services client in investigation of potential sanctions compliance issues in UK affiliate; represented client before UK Financial Conduct Authority (the matter was ultimately resolved with the authorities taking no enforcement action).
Our client, a major large business provider of IT services to the federal government, discovered possible Service Contract Act compliance issues in the operations of a recently acquired subsidiary. We conducted and internal investigation and assisted the client in making a disclosure to the U.S. Department of Labor, which closed the matter without adverse financial or other consequences for our client.
Represented a major automobile manufacturer and its U.S. subsidiaries in connection with a transfer pricing inquiry by U.S. Customs and Border Protection (CBP) and an associated audit.
Assisted major suppliers of office and aeronautics equipment to navigate the Buy American and Trade Agreements Acts, ensuring that the clients’ products are domestic end products, qualifying country end products, designated country end products or U.S.-made end products eligible for sale to the U.S. government.
Analyzed boycott requests received by U.S. companies and their foreign subsidiaries and reporting boycott requests to the U.S. Commerce and Treasury Departments.
Advice to numerous clients regarding compliance with the statutory and contractual pricing obligations under the Veteran’s Health Care Act (VHCA), including performing gap analyses, providing policies and training, and assisting with investigations and disclosures.
Advised multiple clients concerning the Federal Acquisition Regulation’s anti-human trafficking requirements, which were expanded in early 2015. Our advice has included creating employee policies and trainings to facilitate compliance and developing contractor compliance plans that, among other things, provide tools for monitoring subcontractor adherence to human trafficking prohibitions.
Advised multiple clients on matters arising from their negotiation and performance of manufacturing and research and development contracts relating to various pandemic and Chemical, Biological, Radiological and Nuclear (CBRN) threats, including matters relating to government indemnification or liability protection for unusually hazardous risks, compliance with cost standards and principles, and protection of intellectual property.
Advising major Internet companies as to the substantiation required to defend advertising claims made about their products and services.
Advised multiple for-profit clients about domestic sourcing requirements imposed under subgrants and state and local agreements through various Departments of Transportation and Energy appropriations, New Jersey Buy American requirements, and the American Recovery and Reinvestment Act of 2009.
Advising retailers on pricing claims and practices, including the use of the word “free,” “two-for-one” offers, and trial periods with negative cancellation options.
Representing trade associations and individual companies in connection with the FTC’s periodic reviews of advertising practices in the alcoholic beverage industry.
Conducted a detailed review of the human resources operations of a large pharmaceutical company to assess compliance with data protection and privacy laws and regulations in both the U.S. and EU, in anticipation of possible certification under the U.S.-EU Safe Harbor regime. Our extensive written report described potential compliance issues and recommended specific remedial actions.
Assisted global high-technology and financial sector companies with U.S. and other export controls affecting encryption items and high-performance computers.
Developed a comprehensive export controls compliance program to assist a U.S.-based oilfield services company in securing approval under the Commerce Department Special Comprehensive Licensing program.
Advising distributors of prescription drugs and medical devices concerning compliance with the Food, Drug, and Cosmetic Act, FTC Act, and Lanham Act advertising standards.
Led more than a dozen internal investigations for a military aircraft manufacturer, including drafting voluntary disclosures filed with the Departments of State and Commerce that were successfully resolved. Also developed export compliance plans for several of the company’s high-profile international projects.
Conducted an investigation for a major international financial institution with regard to possible breaches of UK and EU financial sanctions and wire transfer regulations by the client’s UK branch.
Assisted a leading life sciences company in the design and implementation of global trade compliance program.
Drafted and implemented a global code of conduct and policies for Harley-Davidson addressing privacy, harassment, discrimination, the use of electronic communications and anti-corruption.
Assisted a life sciences company with international assignments, including relevant cross-border corporate and individual tax risks and immigration requirements.
Provided copyright advice on advertising issues, including with respect to copyright risk-assessment and worked with clients to develop copyright compliance strategies.
Provided guidance to a major technology and manufacturing company in connection with the unauthorized posting of employee personal information on a third-party webpage. Our efforts on behalf of the client included working with Internet service providers to remove the posted information and providing notice to potentially affected individuals and applicable state regulators.
Advised a Japanese technology client on the international employment, pensions and incentives aspects arising on the formation of a joint venture with operations in the US, Asia and Europe.
Conducting a compliance risk assessment of the China operations of a global auto parts company, including overseeing forensic transaction review, and interviews of more than 60 employees at facilities in mainland China and Taiwan.
Conducting internal investigation on behalf of a multinational pharmaceutical company into whistleblower allegations of corruption at its Chinese subsidiary.
Conducted an Iran sanctions investigation for a major pharmaceutical company.
Representing a large automotive parts manufacturer in its response to a show cause notice from a local transit authority customer, addressing questions regarding Disadvantaged Business Enterprise (DBE) participation.
Developed a compliance program for the Asia-Pacific offices of a global energy and industrial company that covers trade controls and anti-corruption laws and regulations and includes guidance on restricted party and embargoed country screening, U.S. export licensing, and recordkeeping requirements.
For a diversified U.S.-based manufacturing company, we developed compliance manuals covering its global operations that addressed export controls, sanctions, and antiboycott compliance, as well as anti-corruption compliance.
Developed a major defense company’s comprehensive export controls compliance best-practices manual covering a range of export control topics. We seconded one of our associates to the company’s core export compliance organization to work on this project, which required synthesizing existing company compliance material and standardizing export compliance practices across a diverse group of businesses.
Press reports accusing our client of using inflated labor categories on a billion dollar contract triggered an eight year False Claims Act (FCA) investigation. Eventually, our appeal to senior attorneys at the U.S. Department of Justice’s Civil Division brought an end to the FCA investigation and cleared the way for the client to negotiate an administrative settlement with the contracting agency resulting in a net payment to the client of millions of dollars.
Counseled our client, a construction material supplier, in connection with a state government construction project partially funded by federal grant funds, and persuaded the prime contractor to accept Mexican-sourced construction material consistent with applicable federal grant restrictions.
Represented numerous U.S. defense and aerospace companies in enforcement investigations before the State Department’s Directorate of Defense Trade Controls and the Department of Justice.
Conducted a detailed review of the human resources operations of a large pharmaceutical company to assess compliance with data protection and privacy laws and regulations in both the US and EU, in anticipation of possible certification under the US-EU Safe Harbor regime. Our extensive written report described potential compliance issues and recommended specific remedial actions.
Representation of TerreStar Networks, one of the companies that won a license to offer mobile satellite service (“MSS”) in the 2 GHz band, on critical milestone compliance and MSS spectrum allocation issues.
March 17, 2017, Global Competition Review
Deborah Garza is quoted in a Global Competition Review article examining the new report released by the U.S. Chamber of Commerce’s International Competition Policy Expert Group. According to Garza, who co-chairs the group, “there is legitimate concern that some countries may be using their competition laws to distort competition and to favour their own interests ...
March 15, 2017, Law360
Deborah Garza is quoted in a Law360 article examining the new report released by the U.S. Chamber of Commerce’s International Competition Policy Expert Group. According to Garza, who co-chairs the group, “The U.S. has long supported the use of antitrust law to promote competitive markets that drive economic development and prosperity.” She adds, “But there is ...
March 14, 2017
WASHINGTON—The International Competition Policy Expert Group (ICPEG), a bipartisan, independent committee of leading experts in trade and competition law and economics formed at the invitation of the U.S. Chamber of Commerce and co-chaired by Covington’s Deborah Garza and Sidley’s Andrew Shoyer, has released a policy analysis and recommendations for a more ...
September 21, 2016
SHANGHAI—China Law & Practice has named Covington as “Regulatory & Compliance Firm of the Year” at its annual award ceremony. The leading Chinese legal publication also recognized Shanghai partner Eric Carlson as “Regulatory & Compliance Lawyer of the Year” and the firm for its role in the “Outbound Deal of the Year,” China National Tire & Rubber’s $7.8 billion ...
August 30, 2016, Inside U.S. Trade
Deborah Garza is quoted in an Inside U.S. Trade article regarding the U.S. Chamber’s newly-assembled group of experts which is expected to develop recommendations for how the next administration and Congress should approach issues related to trade and antitrust policy. According to Garza, due process and transparency obligations are necessary to ensure against ...
August 30, 2016, Global Competition Review
Deborah Garza is quoted in a Global Competition Review article regarding the formation of the U.S. Chamber’s bi-partisan group of leading antitrust and competition experts. According to Garza, there are “across-the-board” bipartisan views when it comes to the issues identified by the U.S. Chamber in the area of international antitrust. She continues, there is “a ...
August 26, 2016
WASHINGTON—The U.S. Chamber of Commerce has announced the formation of a bi-partisan, independent group of leading antitrust and competition experts, which will be co-chaired by Covington’s Deborah Garza and Sidley’s Andrew Shoyer. The group will consider the challenges presented by globally divergent approaches to antitrust and the interplay between competition ...
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