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Experience
FCPA/Anti-Corruption/Fraud Investigations
- Designed and lead an investigation into wide-ranging whistle-blower allegations (posted publicly on Twitter) that employees and third-party sales agents of a client’s recently-acquired subsidiary in the Middle East bribed government officials and others to win media service contracts. The investigation involved a thorough review of the subsidiary’s use, oversight, and compensation of sales agents around the world. Perkins also guided the client through voluntary self-disclosures to the U.S. Department of Justice (DOJ) and U.K. Serious Fraud Office and conducted regular, in-person reporting with both agencies, resulting in the DOJ closing its investigation without charges or penalties.
- Directed a multi-year internal investigation into whistleblower allegations of bribery, corruption and human rights abuses involving a natural resource extraction client’s operations in Indonesia and Ghana. The investigation covered wide-ranging issues, including permits and licensing; use of third-party vendors; charitable foundations; per diems, travel and entertainment for government officials; and company interactions with traditional authorities. As part of the engagement, advised client on remediation measures and conducted multiple meetings with the DOJ and SEC, resulting in declination letters from both agencies.
- Designed and led an investigation into whistle-blower allegations asserting that a global application services company’s employees in India facilitated a bribe through an authorized third-party reseller in order to win a government contract. The investigation focused on whether company employees knowingly authorized high product discounts in order to enable the authorized reseller to use its inflated margin for improper purposes.
- Engaged by a Fortune 200 food and beverage company to conduct an internal investigation into possible violations of the FCPA and Canadian anti-corruption laws relating to improper entertainment, donation, and other contributions to local government officials.
- Managed a multi-year internal FCPA investigation into an automotive client’s manufacturing operations in Egypt, the United Arab Emirates and Saudi Arabia that addressed issues relating to import/export operations, permits and licensing, and use of third-party vendors such as customs clearing agents.
- Headed an internal FCPA investigation into a Fortune 200 company’s operations in Peru, including broad-reaching books and records issues. Following self-reporting of violations, client received a declination letter from the SEC.
- Conducted an internal investigation into allegations of accounting fraud, channel stuffing, and kickback schemes involving China-based employees of a multinational apparel manufacturer.
- Directed an internal investigation into potential manipulation of intercompany accounts for an aerospace and defense industry client that was under investigation by the SEC for potential securities fraud.
Compliance Assessments and Due Diligence
- Engaged by one of the world’s largest natural resources extraction companies to conduct a global compliance assessment of a newly-acquired entity’s FCPA/anti-corruption compliance program. The review focused on evaluating the robustness of the acquired entity’s legacy compliance program; assessing how effectively that program was implemented across twelve operations in North, Central, and South America (including in majority-owned joint ventures); and identifying gaps between the acquired entity’s legacy compliance program and the client’s ethics and compliance program (and advising on gap closure plans).
- Directed anti-corruption-related due diligence for a Fortune 200 client seeking to enter new markets through targeted acquisitions in Africa and South America. As part of matter, interfaced with DOJ regarding a potential acquisition target with known prior FCPA violations.
- Designed and executed properly scoped due diligence process for a Fortune 200 food and beverage client seeking to enter a significant joint venture with a Chinese state-owned entity.
Compliance Counseling and Training
- Drafted and oversaw the implementation of an integrity compliance program (including all supporting policies, procedures, and training materials) for an Africa-based construction company sanctioned by the World Bank for engaging in fraudulent business practices. Our client was released from sanctions at the earliest available release date.
- Tailored and conducted anti-bribery and anti-corruption training for all compliance personnel worldwide for a large mining client.
- Conducted anti-bribery and supply chain compliance training for executives, legal and compliance personnel of an international food service company.
- Analyzed numerous clients’ existing compliance programs and recommended modifications to policies, procedures, due diligence practices and training materials to ensure compliance with the FCPA, U.S. Travel Act and other ABAC and supply chain compliance laws.
