FCPA and Anti-Corruption Compliance Practice

Winston & Strawn is a large international law firm that retains a rare degree of breadth and depth in advising companies on compliance and enforcement matters arising under the U.S. Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. Our anti-corruption team offers a unique and outstanding combination of international transactional attorneys with compliance experience going back to the creation of the FCPA, together with white collar attorneys with recent experience both prosecuting and defending FCPA cases, as well as insider perspectives from recent government service alongside FCPA enforcement officials at the Department of Justice (DOJ) and Securities and Exchange Commission (SEC). We also regularly advise clients on the UK Antibribery Act and other foreign laws implementing the OECD Antibribery Convention, the U.N. Convention Against Corruption, and other international conventions.

Our experience with FCPA matters is longstanding; indeed, some of our attorneys were actively involved in lobbying efforts seeking alternatives to the FCPA prior to its passage in 1977. Our experience is also recent and timely; the co-leader of our team has experience investigating FCPA cases at the DOJ and working closely with the top FCPA enforcement decision-makers at the DOJ and SEC within the past year.

With our unique combination of skills in compliance and enforcement, our attorneys bring a multidisciplinary perspective to the analysis of anti-corruption questions. They include international transactional attorneys with a core practice assisting companies in doing business overseas, as well as litigators experienced in representing clients in internal investigations and civil and criminal enforcement matters. This deep and multidisciplinary experience proves valuable in high-stakes decisions such as choosing whether or not to self-disclose, determining the scope of an internal investigation, negotiating with the DOJ or SEC to decline enforcement, or ensuring an air-tight compliance program that anticipates developments like the Dodd-Frank whistleblower rules.