Foreign Corrupt Practices Act (FCPA) Compliance | McDermott

Anti-Corruption Investigations & Compliance


Effective anticorruption compliance is critical to any company operating internationally. We regularly conduct internal investigations of reported concerns under the Foreign Corrupt Practices Act (FCPA) and other anti-bribery laws to determine the veracity of allegations and to advise companies on responding effectively, including taking steps to reduce opportunities for future misconduct. We also defend companies and individuals in government enforcement and regulatory investigations by authorities in the United States and other countries.

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Our team of lawyers experienced in investigations and defense has successfully represented clients including the following:

  • A Fortune 100 telecommunications company in defense and settlement, creating FCPA precedent, of an SEC and DOJ investigation arising from the Middle East. This matter involved all aspects of the FCPA, including alleged payments to foreign officials, adequacy of books and records, and the presence of internal controls.
  • The chairman of the board of a major international pharmaceutical company in securing dismissal against allegations of FCPA violations in making payments to doctors employed by state-owned hospitals in Taiwan, Latin America and Europe. The dismissal of claims included related securities class action, an Employee Retirement Income Security Act (ERISA) class action, and a shareholder derivative suit arising from the allegations, and avoided criminal prosecution.
  • A US health care corporation, with operations in India, with conducting an FCPA internal investigation and implementing corrective action.

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