FCPA Compliance & Investigations Practice

Now more than ever, it is imperative that companies operating internationally focus on compliance with the Foreign Corrupt Practices Act (FCPA). Largely unenforced for the first 30 years of its existence, in recent years, the FCPA has become a major prosecutorial tool of the U.S. Department of Justice and Securities and Exchange Commission. With fines soaring over $500 million and individuals sentenced to lengthy prison terms, FCPA compliance should be a top priority.

The members of ST&R’s FCPA Compliance & Investigations Practice are among the most experienced and knowledgeable professionals in the FCPA and international anti-corruption arena. For over 10 years, ST&R’s professionals have advised companies around the world on every aspect of anti-corruption compliance including assisting clients with complex multi-jurisdictional investigations. ST&R attorneys have extensive experience conducting investigations and due diligence reviews in the U.S., Asia, Sub-Saharan Africa, Northern-Europe, and the Middle-East.

Our team assists clients by developing effective anti-corruption compliance programs, performing risk assessments, providing training and advising clients when questionable conduct arises. Our attorneys draw on their experiences in the federal government and as in-house counsel to provide clients with insightful advice specifically addressing their operational issues. Our professionals are also well-versed on related laws and issues, such as anti-money laundering laws, requirements under Sarbanes-Oxley, domestic bribery legislation, as well as export controls and sanctions laws.

ST&R’s dedicated team assists in the development, implementation, and maintenance of FCPA compliance programs through the following steps:

► Assessment: The first step in developing an FCPA compliance program is assessing the current state of compliance and obtaining a thorough understanding of company operations, culture, and philosophy. As part of this assessment, ST&R professionals will interview management and employees, conduct group discussions, and distribute questionnaires.

► Communication: Once an accurate picture of your organization is obtained, ST&R professionals will develop an FCPA policy specifically designed for your operations and organizational structure. Compliance tools designed to support the implementation of this policy will also be prepared.

► Training: For a compliance program to be effective, all participants—from a company president to an hourly employee—must be well-informed. ST&R will train your executives, staff, and strategic partners regarding your FCPA policy.

► Implementation: ST&R professionals will work with the various departments in your organization to ensure that the compliance program is implemented at all levels. We will assist with the development of mechanisms such as employee reporting systems and will provide continued support while your company implements its program.

► Auditing: ST&R professionals will periodically audit your compliance program to accurately determine its effectiveness. Once audit results are obtained, we will provide you with a detailed narrative setting forth our assessment and recommendations for improvement. Where an audit system already exists, ST&R will provide an assessment of the quality and effectiveness of the audits against the best practice industry standards, thereby “checking the checkers.”

► Investigation: In the event a questionable payment is suspected, ST&R professionals will conduct on-site investigations anywhere in the world. We will interview employees and agents and coordinate large scale document reviews. We will also provide ongoing investigation reports and analysis to the relevant company personnel and, if required by consent or subpoena, to the investigating agency.

For more information about ST&R’s FCPA Compliance & Investigations Practice please contact: