Counsel to Corporate Monitor of a Multinational Corporation

Represented a DOJ/SEC-appointed Corporate Monitor to oversee a large multinational corporation’s anti-corruption compliance program throughout the Asia-Pacific region (one of approximately 36 such appointments over the last 12 years). We independently tested the effectiveness of the compliance program and recommended best practices to ensure accurate accounting of books and records and implementation of stringent internal controls.

Internal Investigation of FCPA and Anti-Corruption Claims

Conducted internal investigations for large multinational clients related to suspected violations of the FCPA and other anti-corruption laws, including India’s Prevention of Corruption Act, China’s Anti-Unfair Competition Law.

FCPA Disclosure Counsel

Guided clients through FCPA disclosures to the DOJ and the SEC to minimize legal exposure.

Risk Assessments and Compliance Programs

Conducted corporate risk assessments and developed, improved, and implemented company-wide compliance programs and internal controls for operations throughout the Asia-Pacific region.

Foreign Government Inquiry into Hospital Trade Practices

Responded to foreign government inquiries regarding alleged illegal trade practices (gifts, cash payments, rebates, commissions, fees) involving physicians employed at state-owned hospitals and other improper benefits paid to state-owned institutions.

Chinese Government SAIC Investigation

Advised clients in connection with investigations brought by Chinese governmental authorities at the State Administration of Industry & Commerce (SAIC).

Defend Japanese Executive Against Antitrust Claims

Represented an officer of a Japanese corporation in criminal investigations into suspected price-fixing and antitrust violations.

Investigation of Asian Equity Traders

Represented foreign equity traders in China and Thailand in investigations and related litigation arising out of alleged violations of the U.S. securities laws.