Williams & Connolly LLP’s Foreign Corrupt Practices Act experience includes conducting internal investigations for corporate clients that have discovered possible FCPA violations, providing counseling and advice to corporations on FCPA compliance program and due diligence issues, advising about and assisting with voluntary disclosure to federal authorities including the Department of Justice and Securities and Exchange Commission, coordinating with counsel in foreign countries, and defending corporate and individual clients in DOJ and SEC investigations as well as in criminal and civil proceedings. 

The geographical range of the firm’s representations has been varied and has included dealing with FCPA issues in the Middle East, South America, Western Europe, Eastern Europe, Russia, India, Africa and China.

In addition to representing and advising clients in internal and external investigations, Williams & Connolly attorneys have also counseled major corporations on FCPA compliance and due diligence issues.  Firm attorneys worked closely with those clients to develop and implement organizational policies and procedures designed to avoid FCPA compliance problems.  For example, one of the firm's partners developed an FCPA compliance program for a major international financial services firm, oversaw the training and implementation of that program, counseled that corporation on specific matters arising under the program, and engaged in enhanced due diligence for that client with regard to the sale or acquisition of companies that do business in developing and third world countries.  Another partner provided similar oversight over corporate compliance issues, including those related to the FCPA, in his role as the general counsel for a Fortune 500 corporation.  His experience includes working with a broad network of corporate agents in foreign countries, supervising the implementation of a corporate compliance program for that corporation and its subsidiaries, and dealing with SEC and DOJ FCPA investigations for both the parent corporation and its subsidiaries. 

The firm has also dealt with FCPA issues in the context of private, civil litigation.  For example, the firm recently represented a major defense contractor in a civil suit brought by a foreign sovereign against numerous corporate defendants.  FCPA violations by the corporate defendants provided the factual predicate for the substantive claims of the sovereign in that case.  In another civil case involving allegations of FCPA violations, Williams & Connolly represented a global power distribution company in a lawsuit brought by a different foreign sovereign.

The firm also conducts investigations to audit compliance with corporate codes of conduct and applicable statutes and regulatory rules, and counsels boards of directors on creating and monitoring codes of ethical business behavior and on related disclosure issues.

One firm partner authored a leading treatise, Corporate Counsel Guidelines, that is an invaluable resource for in-house counsel. Other partners have served as co-chair of the ABA White Collar Crime Subcommittee on Transnational Criminal Matters, and lecture on FCPA-related issues.  Williams & Connolly also represents companies and their boards of directors in the criminal, civil, and administrative proceedings that arise from corporate governance and compliance issues. In addition to attorneys with experience in these areas, the firm has relationships with experienced investigators, forensic accountants, and subject matter experts who assist in matters when needed.