Global Anti-Corruption

Global Anti-Corruption

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Dentons lawyers regularly handle complex matters arising under the US Foreign Corrupt Practices Act, the UK Bribery Act, and similar anti-corruption laws worldwide.

Our team of seasoned professionals throughout the US, Canada, Latin America and the Caribbean, Europe, Central Asia, Africa, Australia, Asia Pacific and the Middle East represents corporate clients, boards of directors, board committees, hedge funds, partnerships and joint ventures, audit firms and individuals in connection with all aspects of anti-corruption compliance, enforcement and defense. You can also look to us to provide proactive due diligence for both acquirers and targets in mergers and acquisitions transactions to ensure that bribery and anti-corruption risks are thoroughly vetted. Where red flags exist, we have successfully intervened to help correct practices and, where relevant, address concerns about potential liability.

Dentons not only helps you investigate and resolve anti-corruption problems after they have arisen, but we also proactively assist in designing and implementing robust compliance programs. That way you can avoid problems from the outset. Take advantage of our programs that incorporate best practices under the applicable laws to address myriad issues, including business travel and expenses, hospitality and gifts, third-party relationships, and charitable donations and contributions. Our lawyers are at the forefront of anti-corruption issues, frequently conducting seminars and trainings for both private and government entities around the world.

We are experienced practitioners in anti-corruption matters across a wide range of industries. Through our vast global reach, Dentons is a leader in providing a full range of services to you, thereby ensuring that your global business complies fully with the highest international standards and defending you in the case of suspected or actual violation.

Experience

Global logistics and fulfillment company: Represented a client in connection with evaluating FCPA and corruption risk in its Middle East subsidiary operating in high-risk jurisdictions. Representation included legally privileged corporate compliance risk assessment, limited-scope transaction testing and compliance controls review, as well as advising on risk mitigation strategies going forward.
Cross-border anti-corruption investigation: Represented Fresenius Medical Care AG & Co. KGaA, a global health care/medical device company with operations in more than 150 countries, in connection with parallel SEC and the DOJ investigations into multiple alleged violations of the FCPA in Asia, Africa, Europe, and North and South America. Working with our locally based practitioners, our global team helped the client respond to this cross-border investigation and implement new global anti-corruption policies and procedures. The Dentons team ultimately resolved the US criminal inquiry through a non-prosecution agreement with the DOJ and a regulatory order by the SEC.
Global health care company: Advising the client on anti-corruption compliance program development and implementation, including multi-jurisdictional best practices, training and risk mitigation.
Major global engineering firm: Representing major global engineering firm in connection with an investigation by the World Bank Integrity Vice Presidency into alleged corrupt and fraudulent practices by a foreign subsidiary involved in a bank-funded project.
Multinational financial institution: Dentons and Nextlaw In-House Solutions, including a team of former GCs, supported the board and audit committee in their oversight of regulatory compliance programs to fulfill prudential regulator expectations. The client’s audit committee praised our team for the novelty and substantive value of our methodology and findings, which surpassed the capabilities of traditional strategic consultancies while also offering the protection of attorney-client privilege. Our report was provided to and comprehensively reviewed by the regulator. www.nextlawinhouse.com
Multinational pharmaceutical company: Representing the Ukrainian subsidiary of a French multinational company by performing regular anti-corruption due diligence and reputational due diligence with respect to counterparties.

Recognition

Latin Lawyer 250 2024 recommends Dentons Chile as a leading firm

September 14, 2023

Chile: Dentons Chile has achieved the top position in the "Recommended" category in the 25th edition of the Latin Lawyer 250 ranking, based on the number of practices included in this version. For the first time, our labor team and partner Rodrigo Sanhueza have been included in the ranking.

Judith Aron appointed Secretary of the Women's White Collar Defense Association in Germany

September 18, 2019

Dentons partner Judith Aron, Co-head of the Europe Compliance Group, has been appointed Secretary of the German Chapter of the Women’s White Collar Defense Association (WWCDA). She is also a founding member of the German Chapter, which launched on September 12, 2019.

Insights

Former Madagascan presidential aide convicted of bribery after swift NCA investigation

May 23, 2024

United Kingdom: On 10 May 2024, Romy Andrianarisoa, the former Chief of Staff to the President of Madagascar and her associate Philippe Tabuteau, were collectively sentenced to five years and nine months in prison. Both had been convicted of bribery after attempting to solicit a bribe from Gemfields Group Ltd (Gemfields), a UK-based mining company that specialises in the responsible mining of rubies and emeralds.

The Answered and Unanswered Questions of the Expansion of the DOJ’s Corporate Enforcement Policy

September 26, 2022

On September 15, 2022, Deputy Attorney General Lisa O. Monaco delivered public remarks, coupled with publication of an internal memorandum, expanding upon her October 2021 memorandum detailing changes to the Department of Justice’s (“DOJ”) corporate enforcement policies.

The Cullen Commission overview

July 19, 2022

Canada: As predicted in our previous anti-corruption trends to watch in 2022, the Commission of Inquiry into Money Laundering in British Columbia (the Cullen Commission) publicly released its Final Report (the Report) on June 15, 2022.

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