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ISO 37001 Anti-Bribery Management Systems: Substance, Certification, and Open Questions

Speaker(s): Amanda Rigby, Benjamin S. Haley, Jennifer H. Saperstein
Recorded on: Jun. 7, 2017
PLI Program #: 216496


Amanda is a Director in KPMG LLP's Forensic Advisory Services practice.  Amanda has spent the past thirteen years providing fraud risk mitigation, investigation and litigation support services to clients in a variety of industries including retail, consumer products, construction, energy, insurance, manufacturing, health care, pharmaceuticals, banking and for-non-profit.  Amanda also has experience as a portfolio manager for customized asset allocation strategies that included a broad array of asset classes and investment categories.

Ben Haley is an experienced white collar defense practitioner who assists corporations and individuals in complex government enforcement matters and internal investigations.

Mr. Haley has particular expertise with anti-corruption and FCPA matters, where he has guided a number of clients to successful resolutions of SEC and DOJ investigations.

Complementing his investigations practice, Mr. Haley regularly advises clients on a range of anti-corruption compliance issues, including by conducting risk and program assessments, providing advice in connection with proposed transactions, and assisting companies in building and strengthening their anti-corruption compliance programs and controls.

Mr. Haley has extensive experience in FCPA investigations across a range of industries, including automotive and agricultural equipment manufacturing, customs and logistics, consumer products, financial services, information technology, media, gaming, and oil and gas. In these investigations, he has developed deep expertise with complex forensic accounting, internal controls, and transactional issues.

He also routinely manages complex E-discovery projects, including large-scale cross-border data collection and review, and he has expertise in leveraging technology-assisted review/predictive coding in internal and government investigations.

Mr. Haley also has expertise representing special litigation committees and demand evaluation committees in connection with shareholder derivative litigation, including negotiating and crafting settlements and corporate governance enhancements.

In addition to his investigations practice, Mr. Haley represents policyholders on D&O and professional liability matters. He has assisted policyholders across a range of industries in obtaining coverage in connection with securities, derivative, insolvency, trade secret, and franchise litigation.

Representative Matters


  • Led representation of a Fortune 100 manufacturing company in a 17-month FCPA investigation by the SEC that concluded without enforcement action.
  • Successfully resolved a long-running DOJ/SEC investigation involving alleged FCPA violations in Eastern Europe and Latin America by a leading global technology company.
  • Representation of a financial services client in an FCPA investigation relating to hiring practices.
  • Representation of an executive of an automotive manufacturer in a DOJ/SEC investigation into alleged FCPA violations in Eastern Europe.
  • Representation of a leading multinational consumer products company in a DOJ/SEC investigation involving alleged FCPA violations in India.
  • Internal investigation for a manufacturing company relating to imports in Latin America, and related global risk assessment.

Board Committee Investigations

  • Counsel to the Special Litigation Committee of the Board of Directors of Hewlett-Packard Company in shareholder derivative litigation relating to the Board’s response in 2005 and 2006 to leaks of confidential company information.
  • Counsel to the Special Litigation Committee of the Board of Directors of InfoGROUP in connection with shareholder derivative litigation focusing on self-dealing and misuse of corporate assets.
  • Counsel to the Audit Committee of a publicly traded real estate investment trust in an investigation relating to debt covenant compliance and financial reporting issues.

Securities Enforcement

  • In a matter that concluded without enforcement action, representation of a large regional bank in an SEC inquiry concerning mortgage loan repurchase reserves.
  • Representation of a pharmaceutical executive in an SEC/DOJ investigation regarding alleged disclosure, accounting, insider trading, and other securities law violations.
  • Representation of a consulting firm audit committee member in an SEC investigation into accounting irregularities.

Insurance Coverage

  • Counseling clients on D&O and professional liability coverage in connection with investor and franchise litigation and regulatory investigations.
  • Representation of utility in two successful jury trials over coverage for environmental liabilities.

Pro Bono

  • § 1983 action against the city of Covington, Louisiana and members of its police department on behalf of a plaintiff who was wrongfully convicted and exonerated by DNA evidence; obtained over $2 million in total recovery in settlement of this action and related state court litigation.
  • § 1983 action against police and prosecutors in Washington Parish, Louisiana arising out of wrongful conviction of Brady violations.
  • § 1983 action against police and prosecutors in Jefferson Parish, Louisiana involving allegations of Brady violations.
  • Represented an indigent defendant in Maryland on felony handgun charges. Obtained a favorable plea agreement with no jail time where defendant faced mandatory minimum.



University of Maryland School of Law, J.D., 2005

  • Maryland Law Review, Editor in Chief
  • Order of the Coif

Amherst College, B.A., 1999

  • magna cum laude
  • Men's Soccer Team, Captain

Judicial Clerkship

  • Hon. Peter J. Messitte, U.S. District Court, District of Maryland, 2005 - 2006

Bar Admissions

  • District of Columbia
  • Maryland

Jennifer H. Saperstein, vice chair of the Anti-Corruption Practice Group, advises clients on compliance issues arising under anti-corruption laws, including the Foreign Corrupt Practices Act (“FCPA”). An experienced compliance counselor, she frequently conducts risk assessments and compliance program assessments, and has developed anti-corruption compliance programs for clients across a wide range of industries. Ms. Saperstein also leads cross-cutting compliance projects to help companies build and improve their compliance programs across areas of regulatory expertise, bringing together teams of regulatory experts to provide integrated advice.

Ms. Saperstein regularly assists companies with anti-corruption due diligence and compliance integration in connection with acquisitions, asset purchases, joint ventures, and other investment transactions.

Ms. Saperstein also helps corporations with efficient resolution of internal and government investigations into allegations of fraud and corruption.