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The Foreign Corrupt Practices Act and International Anti-Corruption Developments 2018


Speaker(s): Aisling O'Shea, Andrew M. Levine, Asheesh Goel, Bruce H. Searby, Charles E. Cain, Cheryl J. Scarboro, Claudius O. Sokenu, David Johnson, Giovanni Paolo Falcetta, Greta Lichtenbaum, Hui Chen, James Walker, James J. Benjamin, Jr., Jay Holtmeier, Jessica Budoff, Joan Meyer, Jordan A. Thomas, Joseph M. Azam, Karen A. Popp, Kathryn Cameron Atkinson, Kimberly A. Parker, Lucinda A. Low, María Gonzalez Calvet, Mark F. Mendelsohn, Marshall L. Miller, Martin J. Weinstein, Michael D. Hopkins, Michael Sevi, Neil T. Smith, Patricia M. Byrne, Patrick F. Stokes, Paul G. Block, Philip Urofsky, Richard S. Levick, Esq. , Richard W. Grime, Sulaksh R. Shah, Thomas J. Koffer, William B. Jacobson, Zachary Coseglia
Recorded on: Apr. 23, 2018
PLI Program #: 220503

Andrew Levine is a litigation partner who focuses his practice on white collar and regulatory defense, internal investigations and a broad range of complex  commercial litigation. He regularly defends companies in criminal, civil and regulatory enforcement matters and has conducted numerous investigations  throughout the world. Mr. Levine frequently advises companies on compliance matters, including with respect to the U.S. Foreign Corrupt Practices Act, and the assessment and management of risks presented by potential mergers, acquisitions and other transactions. In 2014, Mr. Levine was named to Global Investigations Review’s inaugural “40 Under 40” list of the world’s leading investigations lawyers, and he was recognized in 2013 as a “Rising Star” by the New York Law Journal.

Mr. Levine is recommended for white collar litigation in The Legal 500 US (2013-2014), where clients describe him as “smart, responsive, collaborative and sharp in his advice.” He is ranked as an “Up and Coming” lawyer for Fraud & Corporate Investigations by Chambers Latin America (2016), which notes that “he has great knowledge” and “is especially well-known for his white- collar and investigations expertise.” Latin Lawyer notes Mr. Levine’s “substantial work in Latin America,” recognizing him as one of the top lawyers active on anti-corruption matters in the region.

Before joining Debevoise in 2006, Mr. Levine served as Deputy Counsel to the Independent Inquiry Committee into the United Nations Oil-for-Food Programme, led by Paul A. Volcker, from 2004 to 2005. Mr. Levine spearheaded the investigation into the Security Council’s oversight of Iraq’s humanitarian purchases under the Programme, through which thousands of companies made illicit payments exceeding $1.5 billion to the former Iraqi regime, and he was one of the two principal editors of the Committee’s numerous official reports. Mr. Levine served as a law clerk to the Honorable Dennis Jacobs, U.S. Court of Appeals for the Second Circuit, from 2003 to 2004, and to the Honorable Lewis A. Kaplan, U.S. District Court for the Southern District of New York, from 2002 to 2003.

Mr. Levine received his J.D. from Yale Law School in 2002, where he was a Senior Editor of the Yale Law Journal and Submissions Editor of the Yale Journal of International Law. He obtained his B.A. summa cum laude and Phi Beta Kappa from Yale College in 1997, majoring in Ethics, Politics and Economics. From 1997 to 1999, Mr. Levine worked as a management consultant at McKinsey & Company, advising corporations and nonprofit organizations on issues of strategy, operations and organization.

Mr. Levine is a member of the Criminal Advocacy Committee of the New York City Bar Association and also a member of the Media Law Resource Center. He is a Co-Editor-in-Chief of the firm’s monthly FCPA Update newsletter, and he served as Guest Editor of “Anti-Corruption Survey 2014,” recently published by the International Financial Law Review (IFLR), and again as Co-Contributing Editor of the Anti-Corruption Section of the Latin Lawyer Reference Series.

In addition, Mr. Levine is the author of numerous articles, including “The Latest FCPA Deferred Prosecution Agreement: Will Congress’s New DPA Procedures Reach FCPA DPA’s, And Will Non-U.S. Governments Sue As “Crime Victims” Under The CVRA?,” Main Justice (July, 2015); “Recent Developments In U.S. Domestic Bribery Case Law Reaffirm Various Risks – And Tensions – In FCPA Prosecutions,” Financial Fraud Law Report (February, 2015); “CFPB May Look To NY For Its Own Debt Collection Rules,” Law360 (January, 2015); “Small Country, Big Punch: The Netherlands’ Anti-Bribery Prosecution Of SBM Offshore,” Just Blogs section of Main Justice (December, 2014); “The SEC Noble Prosecution: Takeaways From The O’Rourke, Jackson And Ruehlen Settlements,” Financial Fraud Law Report (November/December, 2014); “DOJ Officials Encourage Companies to Cooperate Against Potentially Culpable Individuals,” Just Blogs section of Main Justice, (October, 2014); “SEC Settles First “Pay-To-Play” Enforcement Action,” Financial Fraud Law Report (October, 2014); “DOJ Proposal Shows Focus on Individuals in Corporate Crime,” Law360, (September, 2014); “Heads of SEC Whistleblower Office and FCPA Unit Warn against Interference with Potential Whistleblowers,”   Financial Fraud Law Dept (June, 2014); “2014 Anti-Corruption Survey: U.S.,” IFLR (June, 2014); “Best Practices in Compliance Programmes,” IFLR (June, 2014); “U.S. District Court Limits Privilege Protections in Compliance Investigations,” Financial Fraud Law Report (June, 2014); “The DOJ’s First Opinion Procedure Release of 2014 Re-Addresses Issues Arising When a Business Partner Becomes a Foreign Official,” Just Blogs section of Main Justice (April, 2014); “Conspiracy and the ‘Indefinite Payments’ Doctrine,” New York Law Journal (February, 2014); “Anti-Corruption Compliance in 2013: Post- Guidance and Signals for the Future,” Financial Fraud Law Report (February, 2014); “Takeaways from the 2013 Corruption Perceptions Index,” Law360 (January, 2014); “Brazil Enacts Long-Pending Anti-Corruption Legislation –  Part Two,” Business Crimes Bulletin (January, 2014); “The Government’s $48 Million ATM Withdrawals: Is It Time To Start Sweating Again?,” Financial Fraud Law Report (January, 2014); “Spotlight on Latin America Business Risks,” Law360 (December, 2013); “Money Laundering Charges In FCPA Cases Bring Unique Risks,” Law360 (November, 2013); “Private Equity & Venture Capital in Latin America – corporate governance,” BVCA International Series (November 2013); “Why the Direct Access Partners Case Matters for Financial Sector Anti- Corruption Compliance,” The FCPA Report (October, 2013); “Spotlight On Southeast Asia,” Financial Fraud Law Report (October, 2013); “The FCPA In Review – Part I: Release of the Government’s Guidance Caps a Year of Disparate Developments,” Financial Fraud Law Report (April, 2013); “Transparency International’s 2012 Corruption Perceptions Index,” Financial Fraud Law Report (April, 2013) and “U.S. Enforcement Agencies Issue Extensive New FCPA Guidance,” Westlaw Journal - White-Collar Crime (February, 2013).

ANDREW M. LEVINE'S SELECT REPRESENTATIONS

White Collar and Regulatory Defense, and Internal Investigations

A Fortune 100 company in civil and criminal investigations regarding possible FCPA violations, resulting in both the DOJ and SEC closing their investigations without bringing any charges or seeking any penalties.

A major bank in connection with investigations relating to its credit card business by the Consumer Financial Protection Bureau and several State Attorneys General.

A leading aircraft engine manufacturer in requests for information made by the UK SFO in connection with intermediaries in overseas markets.

A major multinational conglomerate in an internal investigation relating to FCPA matters in Mexico. 

A private equity firm in parallel investigations by the SEC and the N.Y. Attorney General concerning alleged “pay-to- play” payments involving public pension funds.

A major pharmaceutical  company in an internal review of its compliance program and related  practices.

A special committee of the board of directors of a major  pharmaceutical company in conducting an internal investigation concerning the design and conduct of a clinical trial and the treatment of the trial’s results.

Compliance Advising and Due Diligence

Prudential Financial in its $350 million partnership with LeapFrog  Investments, targeting investments in life insurance companies in Africa.

Various global companies and private equity firms in conducting anti-corruption and trade compliance due diligence relating to potential transactions and investments around the world.

A large private equity firm and its portfolio companies in conducting an anti-corruption and trade compliance risk assessment and in advising on enhanced policies, procedures and controls.

A leading media company in conducting an anti-corruption risk assessment, including with respect to Latin America, and in enhancing relevant policies, procedures and controls.

A major consumer goods  company in providing ongoing advice regarding anti- corruption compliance.

A large global energy company in FCPA due diligence for a multi-billion dollar acquisition, including on-the-ground interviews and forensic testing in North and South America, Europe and Asia.

A US-based private equity firm in anti-corruption advice and due diligence regarding the acquisition of a company with significant operations in Asia.


Complex Civil Litigation

Time Warner Book Group and New York Times editor Timothy L. O’Brien in obtaining  summary  judgment dismissing a libel suit filed by Donald J. Trump regarding the book TrumpNation: The Art of Being The Donald.

Syracuse University in a defamation action brought against it and its head basketball coach, James Boeheim.

A leading retailer in defending various lawsuits involving trademark, copyright, unfair competition, and other claims.

A financial services firm and its CEO in achieving the favorable settlement of a high-profile employment litigation involving alleged breaches of contractual and fiduciary obligations.


Lucinda A. Low is a partner in the Washington, DC office of Steptoe & Johnson LLP, where she heads the firm's Chambers-ranked FCPA and anti-corruption practice and its Compliance, Investigations, Trade and Enforcement Department, and serves on the firm’s Executive Committee. Her practice focuses on the U.S. Foreign Corrupt Practices Act and other anti-corruption laws, as well as other international regulatory compliance issues for multinational businesses, as well as multijurisdictional regulatory and enforcement matters. Ms. Low has extensive experience in internal and government investigations, representing companies, Audit Committees and Board of Directors, and individuals in enforcement matters before the U.S. Department of Justice, Securities and Exchange Commission, and the World Bank and other international financial institutions and foreign authorities. Ms. Low's practice also includes compliance counselling and advice, representation in disputes between commercial parties and host governments, including disputes involving issues of fraud and corruption.  She received a #1 Ranking, Chambers Global 2010-2017, International Trade: FCPA Experts.  Ms. Low is listed in Best Lawyers in America 2012-2018, International Arbitration: Government and International Trade and Finance Law. Ms. Low is in Washington, DC Super Lawyers, International, 2014-2018.

Ms. Low is the Immediate Past President of the American Society of International Law, the Vice Chair of the Board of Directors of the Coalition for Integrity (formerly known as Transparency International-USA) and serves on its Executive Committee, and was the first woman to chair the ABA Section of International Law.  She has received numerous awards for her work. Most recently, in 2017, she received the Outstanding Career award from the Global Investigations Review, which in 2015 named her to its “Women in Investigations:  One Hundred Investigation Specialists from Around the World.” 

Ms. Low was appointed in 2017 by the President of the World Bank to the Panel of Arbitrators of the International Centre for Settlement of Investment Disputes (ICSID); and in 2016 was appointed by President Obama to the ICSID Panel of Conciliators.  She currently sits as President of two ICSID arbitration tribunals and is a member of an annulment committee in a third case.  She also serves on the U.S. Secretary of State’s Advisory Committee on Public International Law.  She also has significant experience as counsel in investor-state and commercial arbitration proceedings, and as an expert witness in disputes raising bribery and corruption and related issues.

Ms. Low was Editor-in-Chief of the UCLA Law Review in 1976-77.  I addition to her J.D. from UCLA Law School, she holds a B.A. from Pomona College, where she designed an inter-disciplinary major in Latin American Studies and Economics.  Ms. Low speaks Portuguese, Spanish and French, and has some knowledge of Russian, Italian and Japanese.


Asheesh Goel is a partner in the Government & Internal Investigations Group in the Chicago office of Kirkland & Ellis LLP. Asheesh focuses his practice on securities enforcement matters, including internal investigations, government investigations and enforcement actions. Over his career, Asheesh has developed substantial depth advising clients on the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act, and other related anti-corruption laws, financial statement and disclosure issues, insider trading and other securities enforcement issues.

As noted recently in Chambers & Partners USA, Asheesh “is recognized for his ‘very insightful’ experience in advising clients” and “has a brilliant mind for identifying issues and has a great ability to present those matters in a way that cuts the complexity down.” Chambers USA has further noted that he is “very thorough and strategic in the way he thinks with a very sharp and well-developed legal mind.” According to them, he has been “described by clients as ‘very experienced and like a guru on FCPA.’”

Chambers & Partners Global noted “peers are impressed with the strategic approach of Asheesh Goel,” “deep regulatory experience sees him regularly handling cross-border securities enforcement matters and FCPA issues” and that “[c]lients admire his knowledge of US law and regard him as a ‘fantastic lawyer, very commercial and practical.’” Chambers Global also said that Asheesh has “extensive experience with the [Indian] subcontinent” and is “great for anti-corruption in China and Latin America as well as India.” 

Asheesh’s work has been featured in publications including the Wall Street Journal, the Financial Times and the Chicago Daily Law Bulletin.

Prior to joining Kirkland, Asheesh was the co-chair of Ropes & Gray’s global anti-corruption and international risks practice as well as the managing partner of Ropes & Gray’s Chicago office. Asheesh also held the position of branch chief with the Securities & Exchange Commission, Division of Enforcement, where he spearheaded numerous high-profile investigations and litigation involving financial statement and disclosure fraud, the Foreign Corrupt Practices Act, insider trading, investment advisory fraud and other potential violations of the securities laws. During his tenure at the SEC, Asheesh received three Special Act Awards for exemplary work on investigations and litigation.


Claudius Sokenu, a former senior counsel with the United States Securities and Exchange Commission, Division of Enforcement, is Deputy General Counsel, Global Head of Litigation, and Global Head of Compliance at Andeavor, a Fortune 100 energy company.  Claudius oversees all of Andeavor’s litigation, internal and government investigations, regulatory compliance, and the ethics and compliance program.

Prior to joining Andeavor, Claudius was a litigation partner at Shearman & Sterling’s New York, Washington, DC, and London offices where his practice focused on representing multinational public and private companies, hedge funds, private equity firms, broker-dealers, investment banks, investment advisers, accounting firms, and their officers, directors, and employees in complex commercial litigations, securities enforcement actions and litigations, including class actions and FINRA arbitrations, white collar criminal defense, derivative actions, congressional investigations, internal investigations, and corporate crisis management.  Claudius has extensive experience in handling delicate high-profile matters that require concurrent representation in the civil, criminal, and political spheres.

Claudius is widely recognized as a leading securities enforcement, white collar crime and Foreign Corrupt Practices Act (FCPA) practitioner.  In nearly two decades in private practice, Claudius represented domestic and multinational compa­nies and their employees in all aspects of FCPA internal investigations, enforcement actions, and compliance matters before the SEC, the United States Department of Justice (DOJ), the United Kingdom’s Serious Fraud Office, and other civil and criminal authorities in the United States and abroad.  Claudius has represented Boards of Directors, Audit Committees, officers, senior management and employees of multinational companies in all anticorruption investigations in dozens of countries and on virtually every continent.

Earlier in his career, Claudius served in the Washington, DC office of the SEC in the Division of Enforcement, on the Honors Program, first as a Staff Attorney and later as Senior Counsel, where he was responsible for handling a broad range of the SEC’s domestic and international enforcement matters, including investigations involving accounting fraud, insider trading, initial public offerings, illicit payments under the FCPA, investment companies and investment advisers, market manipulation, and broker-dealer misconduct.  Claudius was also a member of the Enforcement Division’s FCPA Working Group, which is now known as the FCPA Unit and the Financial Fraud Task Force.

Consistently ranked by Chambers USA and Chambers Global for his investigative, regulatory, and securities enforcement practice (2014, 2013, 2012, 2011), named a Litigation Star by Benchmark Litigation (2016, 2015), Latin Lawyer 250 for White-Collar Crime and Compliance (2013), named a rising star by Ethisphere in its national annual rankings of “Attorneys Who Matter” (2012), named a “Top Lawyer” by The Network Journal (2011), named by Main Justice as one of the Best FCPA Lawyers Outside the Beltway (2011), Diversity & The Bar’s “Leading Law Firm Rainmakers” (2010), and recognized by Securities Law 360 as one of its 10 under 40 (2007), Claudius has represented major companies and/or their officers and directors, including Bank of New York, Bank of America, CIBC World Markets, Northern Trust, Allianz SE, AIG, Cantor Fitzgerald, CVS Caremark, PepsiCo, GlaxoSmithKline, Ernst & Young, Avon Products, Arthur Andersen LLP, Amgen, Walmart, Bristol-Myers Squibb, KraftHeinz, Embraer, Cardinal Health, and TV Azteca before prosecutors and regulators in the United States and abroad and in federal and state courts on bet-the-farm matters.

Claudius was an Adjunct Professor of Law at Georgetown University Law Center in Washington, DC where he taught advanced level securities enforcement and litigation courses.  He has lectured and published extensively on securities enforcement and litigation matters and has been quoted in the financial press on a variety of securities law issues.  Claudius earned his LL.B (with Upper Class Honors) from London South Bank University, an LL.M in Corporate and Commercial Law from the London School of Economics and King’s College London, University of London, and an LL.M in Securities and Financial Regulation from Georgetown University Law Center.


Giovanni Falcetta is a partner in TozziniFreire Advogados’ Compliance and Investigation practice. He has wide experience in conducting internal investigations and structuring compliance programs in both domestic and foreign companies in different industry sectors. He also has solid experience in M&A due diligence and advisory matters, especially those involving risk mitigation in compliance and anti-corruption.

Giovanni actively participated through the Brazilian Institute of Business Law (IBRADEMP) in the legislative process that led to the approval of the Brazilian Anti-corruption Law. His role involved presenting reports to a Special Committee created by The Brazilian Congress to analyze the Bill of Law, leading to several modifications that were incorporated in its final version.


Greta Lichtenbaum is a partner in the Washington, DC office of O’Melveny specializing in compliance with US laws that govern international business transactions and trade, including US economic sanctions, export controls, anti-corruption, foreign investment, money laundering, antiboycott, and customs laws.

In addition to advising clients on the application of these laws, Greta assists in all aspects of managing compliance with these laws, including developing corporate compliance programs, conducting internal investigations relating to potential violations of these laws, and representing companies before the relevant agencies in connection with enforcement proceedings, clearances, license requests, and government inquiries.

Greta has repeatedly been recognized as a leading lawyer in the area of export controls and economic sanctions by Chambers USA (Band 1), Chambers Global (Band 1) and The Legal 500 US. She is a frequent speaker on topics related to international trade and has written extensively on these topics.

Greta graduated from Harvard Law School in 1990. While in law school, she served as Managing Editor of the Harvard Human Rights Journal and a member of the International Law Society.



James Walker is the Wood Group head of Ethics & Compliance with responsibility for Wood’s global compliance programme. James is also the Wood Data Protection officer responsible for Wood’s global data privacy compliance. James is based in London and prior to working with Wood, he was Amec Foster Wheeler’s Head of Ethics & Compliance.   James was also Senior Ethics & Compliance counsel for Tesco plc, a UK based international retailer and previously spent a number of years in private practice for two large global law firms specialising in investigations and compliance activities.

James is a dual UK and US citizen who grew up in Mobile Alabama and was educated in the United States and in the UK. James speaks Spanish, French and Portuguese and is a keen follower of cricket and English football.


Jay Holtmeier is a partner in Wilmer Cutler Pickering Hale and Dorr LLP’s Litigation/Controversy Department, and a member of the Investigations and Criminal Litigation Practice Group. He co-leads the firm's Foreign Corrupt Practices Act and Anti-Corruption Group. He joined the firm in 2004.

Mr. Holtmeier's breadth of experience as a litigator includes service as a federal prosecutor, a senior in-house attorney and a lawyer in private practice. Mr. Holtmeier represents institutions and individuals in complex government and internal investigations and matters of corporate governance and compliance. He has particular expertise in matters involving the Foreign Corrupt Practices Act (FCPA).

In FCPA matters, Mr. Holtmeier has represented clients in government and internal investigations involving conduct in Europe, Asia, the Middle East, Africa, Latin America and Australia. He regularly counsels clients facing difficult FCPA issues in a variety of business contexts, and he has assisted clients in numerous industries in developing and implementing FCPA compliance programs. He devotes substantial attention to advising clients on FCPA problems that arise in the context of mergers and acquisitions, joint ventures and other corporate transactions. He writes and speaks extensively on the subject and is a co-author, with partners Roger Witten, Kimberly Parker, and Erin Sloane, of the leading treatise in the field, Complying with the Foreign Corrupt Practices Act (9th ed. 2016).

As a senior vice president and principal legal counsel with the Reuters Group, Mr. Holtmeier was responsible for all litigation and compliance matters in North and South America. As an assistant US Attorney for the Southern District of New York, he tried several cases to verdict and led extensive grand jury investigations of various crimes, including racketeering, securities fraud, murder, narcotics and counterfeiting. Significant prosecutions included United States v. Jose Muyet, et al., and United States v. Ronald Ocasio, et al., related cases involving more than twenty murders, for which Mr. Holtmeier received the Director's Award for Superior Performance from the Executive Office for US Attorneys, and United States v. Carol Bayless, which received national attention and calls for the impeachment of the presiding US District Judge.

 


Jessica Budoff is an Executive Director in the Legal and Compliance Division of Morgan Stanley, where she serves as Head of Regulatory Counsel/Policies, Procedures and Training for the Institutional Securities Group Compliance team. She previously served as counsel in the Global Financial Crimes Legal Advisory Group, where she advised on anti-corruption matters, including investigations, due diligence, and internal controls. She also supports the Firm’s Global and Americas Franchise Committees.

Prior to joining Morgan Stanley, Jessica was counsel at Akin Gump Strauss Hauer and Feld, where she handled a variety of white collar, securities and bankruptcy litigation matters. Before joining Akin Gump, Jessica served as a law clerk for the Honorable Brian M. Cogan, U.S. District Judge, Eastern District of New York. Jessica graduated from Duke University and Cornell Law School.


Joan Meyer is a partner in the Firm's Washington, DC office. She has handled investigations and resolutions with enforcement authorities involving anti-corruption, securities violations, government contracting and the False Claims Act, and financial frauds for domestic and international companies. Prior to joining the Firm, she was senior counsel to the Deputy Attorney General at the US Department of Justice, where she advised on corporate charging policies, corporate monitorships, and complex criminal litigation and corporate settlements. She also managed the operation of the President's Corporate Fraud Task Force. Joan was the First Assistant United States Attorney and Criminal Chief of the United States Attorney's Office in the Western District of Michigan.

While working as a federal prosecutor, Joan was a recipient of two national awards for her successful prosecutions. She also specialized in civil financial fraud as a senior trial attorney at the Commodity Futures Trading Commission in Washington, DC where she filed federal injunctive and administrative actions against brokerage firms and individual brokers for a variety of solicitation and trading frauds connected to the commodity futures markets. She started her career as a criminal prosecutor in Chicago. Joan is an experienced trial lawyer and has argued many appeals in state and federal courts.

Joan counsels on best practices for compliance with US and international legal requirements and regulations, advises senior management and corporate audit committees on the formulation, conduct, and consequences of enforcement inquiries, including the development of appropriate defenses, disclosures, disciplinary actions and compliance policies. Joan has done extensive work across the globe, with many notable cases from Latin America and advises internal investigations for international companies doing business in Latin America. She has advised and worked with companies in the manufacturing, life sciences, mining and extraction, financial services, transportation and logistics sectors to conduct domestic and global risk assessments, develop and implement compliance programs, create remediation plans and develop emergency/crisis management strategies.  Joan was part of a team that received an award from the Latin Lawyer for one of her cases. She recently co-authored “Corporate Settlement Tools, Deferred Prosecution Agreements, Non-Prosecution Agreements and Cooperation Agreements, published by Bloomberg Law in 2018.


Jordan A. Thomas concentrates his practice on investigating and prosecuting securities fraud on behalf of whistleblowers and institutional clients. As Chair of the Firm's Whistleblower Representation practice, Jordan protects and advocates for whistleblowers throughout the world who have information about possible violations of the federal securities laws. He created, and serves as the editor for, www.secwhistlebloweradvocate.com, a website dedicated to helping responsible organizations establish a culture of integrity and courageous whistleblowers to report possible securities violations-without personal or professional regrets.

A longtime public servant and seasoned trial lawyer, Jordan joined Labaton Sucharow from the Securities and Exchange Commission where he served as an Assistant Director and, previously, as an Assistant Chief Litigation Counsel in the Division of Enforcement. He had a leadership role in the development of the SEC Whistleblower Program, including leading fact-finding visits to other federal agencies with whistleblower programs, drafting the proposed legislation and implementing rules and briefing House and Senate staffs on the proposed legislation. He is also the principal architect and first National Coordinator of the Commission's Cooperation Program, an initiative designed to facilitate and incentivize individuals and companies to self-report securities violations and participate in its investigations and related enforcement actions. In recognition of his important contributions to these national initiatives, while at the SEC, Jordan was a recipient of the Arthur Mathews Award, which recognizes "sustained demonstrated creativity in applying the federal securities laws for the benefit of investors," and, on two occasions, the Law and Policy Award.

Throughout his tenure at the SEC, Jordan was assigned to many of its highest-profile matters such as those involving Enron, Fannie Mae, UBS, and Citigroup. He successfully investigated, litigated and supervised a wide variety of enforcement matters involving violations of the Foreign Corrupt Practices Act, issuer accounting fraud and other disclosure violations, audit failures, insider trading, market manipulations, offering frauds, and broker-dealer, investment adviser and investment company violations. His cases resulted in monetary relief for harmed investors in excess of $35 billion.

Prior to joining the Commission, Jordan was a Trial Attorney at the Department of Justice, where he specialized in complex financial services litigation involving the FDIC and Office of Thrift Supervision. He began his legal career as a Navy Judge Advocate on active duty and continues to serve as a senior officer in its Reserve Law Program. Earlier, Jordan worked as a stockbroker.

Jordan is a board member of the City Bar Fund, which oversees the City Bar Justice Center, the pro bono affiliate of the New York City Bar Association. He also serves as the Chair of the Investor Rights Committee of the District of Columbia Bar.

Throughout his career, Jordan has received numerous awards and honors. Most recently, Jordan was named a 2015 Top Thought Leaders in Trust by Trust! Magazine and a 2014 Superstar by Corporate Responsibility Magazine. In 2012, he was named a Legal Rebel by the American Bar Association Journal in recognition of his trailblazing efforts in the legal field. Ethisphere Institute, an internationally recognized think tank, selected Jordan as a Rising Star in its listing of 2012 Attorneys Who Matter, which recognizes leading practitioners in the world of corporate ethics and compliance. While at the SEC, Jordan received four Chairman's Awards, four Division Director's Awards and a Letter of Commendation from the United States Attorney for the District of Columbia. He is also a decorated military officer, who has twice been awarded the Rear Admiral Hugh H. Howell Award of Excellence-the highest award the Navy can bestow upon a reserve judge advocate. Jordan has received an AV Preeminent rating, the highest attorney rating available, from the publishers of the Martindale-Hubbell legal directory.

Jordan is a nationally sought after writer, speaker and media commentator on securities enforcement, corporate ethics, and whistleblower issues.


Karen A. Popp is the Global Co-Leader of Sidley Austin’s White Collar Practice. Karen has an expansive practice representing companies and individuals in high-profile matters with legal, political and public relations components, such as corporate criminal defense, internal investigationsSEC EnforcementCongressional investigations, OIG and State Attorney General actions, corporate compliance, and litigation.  Chambers Global and Chambers USA recognize her as a leader in the practice area of FCPA/anti-corruption.

Karen represents corporate clients across a host of industries, as well as senior executives and government officials, including a U.S. Presidential Cabinet Member.  She has been retained to lead confidential worldwide internal investigations and defend numerous clients in government investigations.  Karen has extensive experience in FCPA and other anti-corruption matters and has represented clients in investigations in more than 70 countries around the world.

Karen also assists clients in designing and enhancing corporate compliance and ethics programs, and currently serves as outside counsel to several corporate compliance departments. She has conducted global compliance and risk assessments for numerous U.S. and non-U.S. companies. Karen helps companies to respond to internal allegations of wrongdoing, conducts training for Boards of Directors, management, compliance departments and other company personnel, and conducts compliance due diligence regarding corporate acquisitions, joint ventures and other business transactions.   

Before joining Sidley, Karen served in the government as Associate White House Counsel to President Clinton, a lawyer in the Office of Legal Counsel at the U.S. Department of Justice, and Assistant U.S. Attorney in the Eastern District of New York.  She began her career on Wall Street as a litigator at Sullivan & Cromwell after finishing a clerkship for the Honorable Sam J. Ervin III on the U.S. Court of Appeals for the Fourth Circuit.

In additional to Chambers, Karen has been recognized for her White Collar and FCPA practice in Legal 500 US, Benchmark Litigation Star, Global Investigation Review, Who’s Who in Business Crime Defense Lawyers, International Who’s Who of Investigations, The Best Lawyers in America, Washingtonian magazine “Top Lawyers” List, Top 250 Women in Litigation USA, Top 50 Women Lawyers in Washington, D.C., Ethisphere Attorneys Who Matter, Inside Counsel Magazine Leadership Award, and Super Lawyers magazine. 


Kathryn Cameron Atkinson is the Chair of Miller & Chevalier. She has twice been selected as a government-appointed Independent Compliance Monitor. She currently serves as a Department of Justice/Securities and Exchange Commission (DOJ/SEC)-appointed Monitor pursuant to a Foreign Corrupt Practices Act (FCPA) deferred prosecution agreement (DPA). She previously served as Monitor for KBR, Inc. in an FCPA matter settled with the DOJ and SEC. 

Ms. Atkinson has served as faculty in the CEELI Institute’s Investigating and Prosecuting Official Corruption training for foreign prosecutors. She was named to Global Investigation Review's "Women in Investigations 2015," Latinvex's "Latin America's Top 100 Female Lawyers: FCPA and Fraud" (2017), and the Ethisphere Institute's "Attorneys Who Matter" list (2015, 2017). "The 'extremely knowledgeable and experienced' Kathryn Cameron Atkinson 'brings a great approach to difficult situations,'" notes Chambers USA and Chambers Global, where she is ranked Band 2 in FCPA (Nationwide).


María Gonzalez Calvet is Executive Counsel, Global Investigations, for General Electric supporting Latin America.  Previously, María was a trial attorney in the Department of Justice’s FCPA Unit where she led the Direct Access Partners, Embraer, and LATAM Air matters. Before DOJ, María worked at Morgan Lewis focusing on white collar defense and complex litigation.  She attended the University of Pennsylvania Law School and clerked for the Honorable Legrome Davis on the EDPA.  María obtained her Bachelor’s degree from the University of Pennsylvania and her Master’s degree in English from Penn State.  She has held leadership roles in the Pennsylvania and National Hispanic Bar Associations. Notably, she was counsel to the HNBA before the Senate Judiciary Committee during the confirmation of Justice Sonia Sotomayor. She received the 2010 Women of Distinction Award from the Legal Intelligencer and the Pennsylvania Bar Association’s Pro Bono Award in 2008.  At GE, she earned a 2016 CEO Award and Gold Awards in 2016 and 2015. María was also recognized by Global Investigations Review in the 2017 In House Counsel Survey.


Marshall L. Miller is Of Counsel in the Litigation Department at Wachtell, Lipton, Rosen & Katz. His practice concentrates on representing and advising corporations, board members, and senior executives with respect to internal investigations, cybersecurity, regulatory compliance, criminal defense, and civil litigation.

Before joining the firm, Mr. Miller served as the Principal Deputy Assistant Attorney General and Chief of Staff of the Criminal Division of the Department of Justice, where he supervised over 600 federal prosecutors, oversaw DOJ’s highest profile criminal prosecutions, and helped determine and implement DOJ priorities and policies. In that position, Mr. Miller supervised the Computer Crimes & Intellectual Property Section (CCIPS), DOJ’s flagship unit that combats cybercrime, and oversaw the creation and launch of its Cybersecurity Unit. He testified on Capitol Hill, briefed Congressional staff, and advised executive branch officials on initiatives ranging from improving cybersecurity to combating kleptocracy. Mr. Miller personally managed and coordinated the successful Senate confirmation process for the Attorney General of the United States.

Mr. Miller joined DOJ’s Criminal Division from the United States Attorney’s Office for the Eastern District of New York (EDNY), where he worked as an Assistant United States Attorney for approximately 12 years. At the EDNY, Mr. Miller served in a number of leadership positions, ultimately as the Chief of the Criminal Division, overseeing all of its criminal prosecutions and the launch of the Office’s National Security & Cybercrime section.

At DOJ, Mr. Miller conducted and supervised the successful prosecution of some of the world’s most significant corporations, corporate executives, cybercriminals, members of Congress, and international terrorists. For his work, Mr. Miller received a number of DOJ’s highest awards, including an Attorney General’s Award for Excellence in Furthering the Interests of National Security and a Director’s Award for Superior Performance. He has also received awards from the New York City Bar Association, the Director of National Intelligence, the Federal Law Enforcement Foundation, and the National Association of Former United States Attorneys.

Mr. Miller co-founded the EDNY Federal Criminal Prosecution Clinic at NYU Law School, and taught as a full-time and adjunct law professor at NYU from 2003 through 2012. Mr. Miller clerked for United States District Judge Allyne R. Ross. He earned both his J.D. and B.A. from Yale.


Martin J. Weinstein is a partner in Willkie Farr & Gallagher LLP’s Litigation Department, Chair of the Compliance, Investigations & Enforcement Practice Group and a member of the firm’s Executive Committee. Mr. Weinstein graduated from Dartmouth College and the University of Virginia School of Law. Mr. Weinstein represents corporations, organizations and individuals in a wide variety of sensitive matters ranging from bribery, fraud, whistleblower and corruption matters worldwide to Congressional inquiries into campaign contributions, as well as the last Pete Rose investigation on behalf of the Commissioner of Major League Baseball. His practice has covered almost every major enforcement, compliance or financial fraud topic in almost every industry, spanning over 60 countries in every region of the world. Mr. Weinstein is a widely recognized authority in the US Foreign Corrupt Practices Act (FCPA), is recognized in Chambers and has been an expert witness on a number of occasions. He is co-author of The Foreign Corrupt Practices Act: Compliance, Investigations and Enforcement, a comprehensive practitioner’s handbook. He is a community leader serving on a variety of boards including the Chesapeake Bay Trust, Washington, DC Community Foundation and the Landon School.


Michael D. Hopkins has served as Chief Compliance Officer of LyondellBasell Industries N.V. since joining the company in October 2010.  He is responsible for all facets of the company’s compliance function including designing and implementing systems and processes to prevent, detect, and remediate compliance related issues.  Hopkins has extensive international experience as a result of undertaking various compliance related activities in over 40 countries.  In addition Hopkins has been responsible for conducting and resolving numerous internal and government investigations.

Mr. Hopkins previously served as Vice President and Chief Compliance Officer of Smith International, Inc. from 2008 to 2010 and Vice President and General Counsel of Smith Technologies from 2005 to 2008.  Prior to joining in house practice as counsel for Stewart & Stevenson Inc. in 2001, Mr. Hopkins was with Bracewell & Patterson LLP n/k/a Bracewell.  Mr. Hopkins is a graduate of the University of Georgia and earned a J.D., cum laude, and MBA from the University of Houston.


Neil Smith is a partner in the firm’s Boston office, where he is member of the Investigations, Enforcement and White collar practice group.  His practice focuses on government investigations, securities enforcement, internal investigations, financial regulatory enforcement, and white collar defense.  In particular, he has extensive experience conducting global investigations involving violations of the Foreign Corrupt Practices Act and other anti-corruption laws. 

Mr. Smith represents corporations and individuals in a wide range of criminal and civil matters, including investigations conducted by the U.S. Department of Justice and Securities and Exchange Commission, and other federal and state criminal and civil regulatory authorities.  His practice also involves counseling clients on best practices and risk mitigation strategies in securities regulation, anti-corruption policies, and FCPA compliance. 

Prior to joining the firm, Mr. Smith served as senior counsel in the Enforcement Division of the U.S. Securities and Exchange Commission (“SEC”) for more than six years, where he was a member of the SEC’s Foreign Corrupt Practices Act specialized unit.  He is a recognized expert in FCPA enforcement and a frequent speaker at industry conferences.  His experience includes extensive collaboration with U.S. and foreign criminal and regulatory authorities in complex, cross-border investigations.  While at the SEC, Mr. Smith also had extensive experience investigating financial services firms and other companies for violations including securities fraud, investor misrepresentations, and marketing violations.  In 2017, he was the recipient of the Ferdinand Pecora Award for tenacity, creativity and efficiency under difficult circumstances, and the Director of Enforcement Award for outstanding service in 2016.

Mr. Smith earned his J.D. summa cum laude from Boston College Law School and B.A. from Dartmouth College. 


Patrick F. Stokes is a litigation partner in Gibson, Dunn & Crutcher's Washington, D.C. office. He is a member of the firm's White Collar Defense and Investigations, Securities Enforcement, and Litigation Practice Groups.

Mr. Stokes' practice focuses on internal corporate investigations, compliance reviews, government investigations, and enforcement actions regarding corruption, securities fraud, and financial institutions fraud. He has tried more than 30 federal jury trials as first chair, including high-profile white-collar cases, and handled 16 appeals before the U.S. Court of Appeals for the Fourth Circuit. Mr. Stokes is equally comfortable leading confidential internal investigations, negotiating with government enforcement authorities, or advocating in court proceedings.

Prior to joining Gibson Dunn, Mr. Stokes spent nearly 18 years with the U.S. Department of Justice (DOJ). From 2014 to 2016 he headed the FCPA Unit, managing the DOJ's FCPA enforcement program and all criminal FCPA matters throughout the United States, covering every significant business sector, and including investigations, trials, and the assessment of corporate anti-corruption compliance programs and monitorships. Mr. Stokes also served as the DOJ's principal representative at the OECD Working Group on Bribery working with law enforcement and policy setters from 41 signatory countries on anti-corruption enforcement policy issues.

From 2010 to 2014, he served as Co-Chief of the DOJ's Securities and Financial Fraud Unit. In this role, he oversaw investigations and prosecutions of financial fraud schemes involving accounting fraud, benchmark interest rate manipulations, insider trading, market manipulation, Troubled Asset Relief Program (TARP) fraud, government procurement fraud, and large-scale mortgage fraud, among others.

From 2002 to 2008, Mr. Stokes served as an Assistant United States Attorney in the Eastern District of Virginia, where he prosecuted a wide variety of financial fraud, immigration, and violent crime cases. From 1998 to 2002, he served in the DOJ's Tax Division as a trial attorney in the Western Criminal Enforcement Section.

Mr. Stokes received various awards while at the DOJ, including the Attorney General's Distinguished Service Award in 2013 and 2014 and the Assistant Attorney General's Exceptional Service Award (Criminal Division) in 2011 and 2014.

Mr. Stokes received his bachelor's degree and Juris Doctor from the University of Virginia, where he was an editorial board member of the Virginia Journal of Social Policy and the Law.

Mr. Stokes is admitted to practice in the District of Columbia, the District of Maryland, the Eastern District of Virginia, the Western District of Washington, and the Fourth Circuit.


Paul G. Block is an Assistant Director in the Boston Regional Office of the U.S. Securities and Exchange Commission.  Mr. Block is a member of the Enforcement Division’s Foreign Corrupt Practices Act Unit and supervises investigations conducted by the FCPA Unit located in Boston.  He previously served in the Boston office as a Branch Chief, a Senior Investigations Counsel in the FCPA Unit, and as a Senior Enforcement Counsel.  In addition to matters involving the Foreign Corrupt Practices Act, Mr. Block has investigated and supervised the investigation of a variety of federal securities laws violations, including insider trading, market manipulation, investment adviser, and accounting fraud. 

Prior to joining the SEC in 1999, Mr. Block was a Senior Attorney with the U.S. Federal Trade Commission’s Boston Regional Office, which had responsibility for enforcing the federal antitrust and consumer protection laws in the New England states.  Mr. Block obtained his bachelor’s degree from the American University in Washington, D.C. and his law degree from the Boston University School of Law.


Philip Urofsky is head of the global anti-corruption practice at Shearman & Sterling LLP, where he counsels Boards, companies, and individuals concerning  government investigations, internal investigations, and compliance controls with respect to the Foreign Corrupt Practices Act, financial sanctions regulations, and other white collar laws and regulations.   Formerly the lead FCPA trial attorney at the Department of Justice, he was responsible for many FCPA investigations and prosecutions, helped negotiate the Council of Europe and OECD Conventions and was designated as the U.S. expert for the OECD Working Group on Bribery’s peer review process, and was the principal drafter of the DOJ’s Federal Principles of Corporate Prosecution (the “Holder Memo”) (although he disclaims any responsibility for what the government did with it afterwards).  Mr. Urofsky writes and speaks widely on topics related to the design and implementation of compliance programs and sanctions and anti-corruption enforcement trends and patterns. 


Richard Levick, Esq. is Chairman & CEO of LEVICK, representing countries and companies in the highest-stakes global communications matters – the Venezuelan crisis; Qatar; the Chinese trade war; the Gulf oil spill; Guantanamo Bay, the Catholic Church and many others.

Mr. Levick was honored multiple times on the prestigious list of “The 100 Most Influential People in the Boardroom” and has been named to multiple professional Halls of Fame for lifetime achievement.

He is the co-author of four books and is a regular commentator on television and in print. Mr. Levick speaks all over the world; at West Point, The Army War College and teaches at Fordham Law School.


Richard W. Grime is a litigation partner in the Washington office of Gibson, Dunn & Crutcher’s Washington, DC office and a member of the White Collar Defense and Investigations Practice Group and the Securities Enforcement Practice Group. 

Mr. Grime’s practice focuses on representing companies and individuals in corruption, accounting fraud, and securities enforcement matters before the Securities and Exchange Commission and the Department of Justice.  Mr. Grime also conducts internal investigations and counsels clients on compliance and corporate governance matters with a particular focus on corruption investigations.

Prior to joining Gibson Dunn, Richard spent over nine years in the Division of Enforcement at the Securities and Exchange Commission in Washington, DC.  In his last four years at the Commission he was an Assistant Director. Mr. Grime is currently highly ranked in Chambers USA Nationwide FCPA and Chambers Global FCPA and was recently selected by his peers for inclusion in The Best Lawyers in America© 2016 in the field of Criminal Defense: White Collar.  He is also a longstanding and frequent speaker to legal and industry practitioners particularly on anti-corruption and securities enforcement topics.

Mr. Grime received his law degree from Oxford University.


William B. Jacobson is a partner in the White Collar and Criminal Investigations group at Orrick, Herrington and Sutcliffe, LLP, based in Washington, D.C.  From 2009 until July 2014, Billy was the Senior Vice President, Co-General Counsel and Chief Compliance Officer for Weatherford International, a large oilfield services company with operations in 100+ countries.  Billy served as a federal prosecutor at the Fraud Section of the U.S. Department of Justice’s Criminal Division for approximately 6 years.  His last stint at DOJ was as Assistant Chief for FCPA Enforcement where he was responsible for roughly half of all FCPA investigations and prosecutions.  In this role, he also spent a considerable amount of time liaising with the SEC, FBI and foreign prosecutors, including attending meetings of the OECD Working Group on Bribery.   Billy started his career prosecuting street crime in New York City. 


Zachary Coseglia is an Assistant General Counsel and Head of Pfizer’s Global Compliance Monitoring and Analytics Program.  In his role, Mr. Coseglia and his team of lawyers, data scientists and experienced compliance professionals are responsible for developing and executing on a global monitoring strategy that leverages technology and advanced analytics for early detection and effective communication of emerging risks.  His team also partners closely with business leaders and other compliance colleagues to develop and deploy self-monitoring initiatives imbedded within the business.

Mr. Coseglia previously led Pfizer’s compliance investigations team in China. Prior to Pfizer, Mr. Coseglia was associated with DLA Piper, where he managed large-scale internal anti-corruption investigations and other internal reviews involving financial fraud, manufacturing operations, research and development issues, and pharmaceutical product promotion. Mr. Coseglia graduated from Boston University School of Law in 2005, and is a member of the bars of Massachusetts and Rhode Island. In 2012, Mr. Coseglia was honored by his peers as one of the Top 20 young lawyers practicing in Massachusetts. He regularly speaks about internal compliance investigations, compliance monitoring, and the role of technology and innovation in compliance.  


A partner in the Litigation Department, Mark Mendelsohn is co-chair of the Anti-Corruption & FCPA Group, and a member of the White Collar and Regulatory Defense, Internal Investigations, and Securities Litigation Practice Groups. Prior to joining Paul, Weiss, Mark served as the deputy chief of the Fraud Section of the Criminal Division of the United States Department of Justice (DOJ), and is internationally acknowledged and respected as the architect and key enforcement official of DOJ’s modern Foreign Corrupt Practices Act (FCPA) enforcement program.

Mark’s practice emphasizes white collar matters, internal corporate investigations, and compliance counseling. He regularly represents clients in FCPA and corruption-related internal investigations, designing and implementing compliance programs, transactional anti-corruption diligence, and responding to and defending against government investigations, prosecutions, and trials on behalf of both business entities and individuals.

As deputy chief of the Fraud Section from 2005 to 2010, Mark was responsible for overseeing all DOJ investigations and prosecutions under the FCPA, and for supervising a team of trial attorneys with respect to investigations and prosecutions of a wide variety of federal white collar crimes including money laundering, mail and wire fraud, procurement fraud, Arms Export Control Act and International Traffic in Arms Regulations (ITAR) violations, and violations of economic and trade sanctions laws and regulations, including with respect to the United Nations Oil for Food Program. During his tenure, Mark handled hundreds of voluntary disclosures of illicit corporate payments, worked closely with attorneys in the Division of Enforcement at the U.S. Securities and Exchange Commission, helped establish and worked closely with the Federal Bureau of Investigation’s FCPA squad at the Washington Field Office, negotiated numerous corporate plea, deferred and non-prosecution agreements on behalf of DOJ, and participated in the appointment of, interaction with, and reporting by more than 16 corporate compliance monitors. Mark led an effort to forge closer working relationships with foreign regulators in connection with transnational bribery cases, resulting in coordinated settlements with the Munich Public Prosecutor in Germany in the Siemens prosecutions and coordinated settlements with the U.K.’s Serious Fraud Office in the BAE and Innospec prosecutions, among others. Mark was also responsible for  administering DOJ’s FCPA Opinion Release Procedure, including issuing the seminal opinion on FCPA transactional diligence and successor liability (Op. Rel. 08-02).

In addition to case-related responsibilities, Mark had significant policy responsibilities, including principal policy responsibilities related to the Organisation for Economic Co-operation and Development (OECD) Anti-bribery Convention. As a member of the U.S. delegation to the OECD Bribery Working Group, Mark served as a lead examiner for the follow-up review of Japan’s implementation of the OECD Anti-bribery Convention, played a key role in peer review of the United Kingdom including consultation regarding its Bribery Act of 2010, negotiated the 2009 Anti-Bribery Recommendation, and played a leading role in the drafting and adoption of the OECD’s “Good Practice Guidance on Internal Controls, Ethics and Compliance.”

During his tenure administering the DOJ’s FCPA enforcement program, the DOJ brought more than 50 prosecutions against corporations for violations of the FCPA and related offenses, resulting in more than $1.5 billion in criminal penalties. During that same period, DOJ brought approximately 80 prosecutions against individuals. Among the notable prosecutions were the following: U.S. v. Siemens AG, et al.; U.S. v. Kellogg Brown & Root, LLC and U.S. v. Albert “Jack” Stanley; U.S. v. Congressman William J. Jefferson; U.S. v. BAE Systems plc; U.S. v. Baker Hughes, et al.; U.S. v. Titan Corp.; U.S. v. Statoil ASA; U.S. v. Monsanto; Lucent Technologies, Inc.; U.S. v. Willbros Group, Inc., et al.; U.S. v. Christian Sapsizian, et al.; U.S. v. Viktor Kozeny and Frederick Bourke, Jr.; U.S. v. Gerald and Patricia Green; U.S. v. Innospec, Inc.; and U.S. v. Daimler AG.

Prior to joining the Fraud Section, Mark was senior counsel in the DOJ’s Computer Crime and Intellectual Property Section in Washington, D.C., and prior to that served for nearly six years as an assistant U.S. attorney in the U.S. Attorney’s Office in the Southern District of New York. During his service with the U.S. Attorney’s Office, Mark tried numerous cases to verdict and argued several appeals before the United States Court of Appeals for the Second Circuit. As a federal prosecutor, Mark was a recipient of the Attorney General’s Award for Distinguished Service for the “Investigation into Corrupt Payments by Siemens AG,” and a recipient of the Assistant Attorney General’s Award for “The Safeguarding and Maintenance of Confidence in the American Marketplace.” Mark has been recognized by Ethisphere Institute in 2011 as a “Top Gun” among “Attorneys Who Matter,” in 2009 as a “Government Star” among “Attorneys Who Matter In Corporate Compliance,” and in 2007 and 2008 as one of the “100 Most Influential People in Business Ethics.” Mark has been selected to Lawdragon “500 Leading Lawyers in America” numerous times. Mark is also ranked by Chambers for his work as an FCPA practitioner.

Mark has spoken frequently as a faculty member, panelist and keynote speaker at numerous FCPA, anti-corruption, corporate compliance, securities fraud, money laundering, and white collar crime programs and conferences. He teaches International Criminal Law as a visiting professor at the University of Virginia School of Law and has also been an adjunct lecturer-in-law at Columbia Law School. Mark is member of the Edward Bennett Williams Inn of Court and a member of the Board of Directors of Transparency International-USA.


Cheryl Scarboro, formerly an Associate Director in the SEC’s Division of Enforcement and the first Chief of the SEC’s FCPA Unit, is a Partner in the Washington, D.C. office of Simpson Thacher & Bartlett LLP and a member of the Firm’s Government and Internal Investigations Practice. She represents corporations, financial institutions and individuals in government investigations and other regulatory enforcement proceedings. Cheryl handles sensitive internal investigations on behalf of management, boards, and special committees, and routinely counsels clients on compliance programs, SEC reporting, disclosure and corporate governance requirements. 

Selected representations include:

  • Representation of a former employee of a mining company in an action brought by the SEC alleging accounting violations relating to the value of a project in Africa. 
  • Special Litigation Committee of a Fortune 50 company in an internal investigation related to the Company’s handling of allegations of sexual harassment;
  • Global telecommunications company in an SEC/DOJ inquiry regarding alleged payments to government officials in various countries;
  • Various senior executives in connection with SEC/DOJ investigations into potential FCPA violations;
  • Large Asian company in connection with SEC investigation of potential FCPA violations;
  • Special committee of a large Chinese company in an independent review of allegations of fraud; and
  • Major mining consortium in South America in connection with the design and implementation of an enhanced anti-corruption program.

She is recognized as one of the “25 Most Influential Women in Securities Law” by Law360, and is consistently listed in the “Top 250 Women in Litigation” by Benchmark Litigation where market commentators describe her “huge place in the FCPA world”; “She was the leader of the SEC in the FCPA field and brings a wealth of experience to the table.” Cheryl was also recently named to Savoy Magazine’s “2018 Most Influential Black Lawyers” list. In addition, Cheryl was named to the “Enforcement 40” by the Securities Enforcement Forum, she is consistently recommended by The Legal 500 in white collar, and was named a National and Washington, D.C. “Litigation Star” by Euromoney's Benchmark Litigation in white collar.

She earned her J.D. from Duke University School of Law in 1989 and her B.A. from University of Alabama in Huntsville in 1986.

 

 


From January 2018 to the present, Bruce has been a Partner in Searby LLP, a law firm with offices in Washington, DC and Cleveland, OH.  Bruce provides defense representation in matters under criminal investigation, as well as counsel to companies and individuals in complying with the provisions of the Foreign Corrupt Practices Act (FCPA) and other federal laws.  Bruce also works as an advisor to an environmental policy shop on rule-of-law issues.

From 2016 to 2017, Bruce was a Trial Attorney with the U.S. Department of Justice, Criminal Division, Fraud Section in Washington, DC, in a unit prosecuting FCPA cases. He investigated and successfully charged corrupt conduct, as well as worked with foreign and domestic law enforcement agencies towards repatriating corruption proceeds to victims.

From 2011 to 2016, Bruce was Counsel at Paul, Weiss, Rifkind, Wharton & Garrison LLP in Washington, DC.  He represented corporate and individual clients in FCPA and corruption-related internal investigations, responded to and defended against enforcement and sanctions proceedings, designed and implemented compliance programs, conducted transactional anti-corruption diligence, and structured third-party relationships.

From 2002 to 2011, Bruce was an Assistant United States Attorney in the Criminal Division of the U.S. Attorney’s Office in Los Angeles. Bruce specialized in investigating and trying corruption cases. He successfully prosecuted U.S. individuals for bribery in Thailand, resulting in the seizure of millions of dollars in ill-gotten gains. He brought the first-ever charge against a bribe-taking former official for international promotion money laundering (a theory since used in other DOJ cases). Bruce received the Director’s Award from the Executive Office of U.S. Attorneys for an investigation and trial of a corrupt local mayor.

From 1997 to 2001, Bruce worked at Munger, Tolles & Olson LLP in Los Angeles as an associate.   He worked on securities cases (including the suit against Merrill Lynch over the massive 1994 Orange County bankruptcy), other civil litigation, and white-collar crime matters involving the FCPA and export-control statutes. 

From 1995 to 1996, Bruce clerked for the Hon. A. Wallace Tashima on the United States District Court for the Central District of California and then, upon the judge’s elevation, on the United States Court of Appeals for the Ninth Circuit.

Bruce has spoken at events sponsored by ABA White Collar Crime Institute, The World Bank, Transparency International, the American Society of International Law, the Wharton School of Business, and the Thai National Anti-Corruption Commission.  He taught a course for foreign law enforcement on anti-corruption investigation at the CEELI Institute in Prague.

Barred in California and D.C., Bruce is a graduate of Princeton University (magna cum laude) and University of Michigan Law School (Michigan Law Review and Order of the Coif).


Michael Sevi is the Deputy Chief Compliance Officer of Marsh & McLennan Companies, a Fortune 200 company with over 70,000 employees, 16 billion in revenue and operations in over 130 countries.  He has global responsibility for internal investigations, anti-corruption and compliance policies, training and monitoring.  Before joining MMC, Michael served as a Deputy Chief of Staff to the Governor of Florida overseeing insurance, banking and pension policy.  Previously, he served as the Governor’s Assistant General Counsel and Chief Ethics Officer.  He represented the Governor before the Florida Commission on Ethics and acted as legal counsel to the state’s Chief Inspector General.  Michael began his career in the Washington, D.C. office of Hogan Lovells, working in both the litigation and internal investigations groups.  He graduated from Dartmouth College and Harvard Law School.


Sulaksh is a partner in PwC's Forensic Services Practice in Washington D.C. and the co-leader of their Investigations practice.

Sulaksh has approximately 16 years of public accounting experience.  His practice focusses on anti-corruption/FCPA matters, including internal investigations, compliance programs, and due diligence.  Sulaksh has represented clients before the United States Department of Justice as well as the Securities and Exchange Commission.

Sulaksh has worked on anti-corruption/FCPA matters in Africa, Asia, Latin America, Europe and the Middle East.  In particular, he has anti-corruption/FCPA experience in pharmaceutical/medical products, manufacturing, industrial products, retail and consumer, hospitality, and the oil and gas industry.

He frequently speaks on anti-corruption/FCPA topics and has been a featured speaker at national and international conferences, including American Conference Institute events.  Sulaksh has instructed at various universities, including but not limited to Georgetown Law School, University of Virginia, University of Missouri, and DePaul University.

From 1998 through 2001, Sulaksh assisted the Kuwait Public Authority for Assessment of Compensation for Damages Resulting from Iraqi Aggression (PAAC) in preparing claims for the Government of Kuwait, which arose from the Iraqi invasion, totaling to USD 131 billion for submission to the United Nations Compensation Commission.

Sulaksh is a licensed Certified Public Accountant (CPA) in Illinois and Virginia.  He is also a Certified Fraud Examiner, and Certified in Financial Forensics (CFF).  Sulaksh is a Bachelor of Commerce from the University of Mumbai, India.  He is also an associate (non-lawyer) member of the American Bar Association’s Criminal Justice and International Law sections.

Sulaksh is also a Board Member of MATHCOUNTS, a 501 (c) 3 tax-exempt organization that promotes middle school mathematics achievement through grassroots involvement in every U.S. state and territory.


James J. Benjamin Jr., a leader of Akin Gump’s securities enforcement and litigation practice group, represents institutional and individual clients in a wide variety of government and regulatory investigations and litigation. He has served as lead counsel in numerous internal investigations and has conducted numerous jury trials. He has been recognized as a leading lawyer by Chambers USA: America’s Leading Lawyers for Business in the areas of white-collar crime and government investigations.  Before joining Akin Gump, Mr. Benjamin served for more than five years as a federal prosecutor in the U.S. Attorney’s Office for the Southern District of New York, where he served as deputy chief appellate attorney and as a member of the Securities and Commodities Fraud Task Force. Mr. Benjamin previously served as a law clerk at the U.S. Supreme Court for Justices Lewis F. Powell Jr. and John Paul Stevens. He received his A.B. magna cum laude in 1987 from Dartmouth College, where he was a member of Phi Beta Kappa, and he earned his J.D. with honors in 1990 from the University of Virginia School of Law, where he was the research and projects editor of the Virginia Law Review.


Joseph Azam is Senior Vice President & Global Chief Compliance & Ethics Officer at Infor, where he heads global compliance and oversees internal investigations. Prior to his role with Infor, Joe was Group Chief Compliance Officer at News Corp in New York. Prior to that, Joe served as SVP & Associate General Counsel, Global Anti-Bribery at London-based HSBC has held similar in-house positions at Accenture and Oracle. Joe’s compliance counseling and investigations engagements have included in-country work throughout the Americas, Europe, Asia, the Middle East and Africa. He began his practice at Willkie Farr & Gallagher LLP in New York. Joe is a graduate of the University of California, Hastings College of the Law, where he serves on the Board of Governors, and holds an M.A. and B.A. from New York University. He has been a contributor for MTV News, Ethisphere Magazine, the San Francisco Chronicle the LA Times, and Lucky Peach Magazine.


Kimberly A. Parker is a partner at Wilmer Cutler Pickering Hale and Dorr in Washington.  Ms. Parker co-leads the firm’s Foreign Corrupt Practices Act (FCPA) and Anti-Corruption Practice.  She has represented companies and individuals in a variety of FCPA enforcement matters, including defense company Armor Holdings in its July 2011 FCPA settlement involving conduct related to the United Nations, oil driller Helmerich & Payne in its July 2009 FCPA involving payments to customs officials in Argentina and Venezuela, and the Titan Corporation in its landmark 2005 FCPA case.  She has conducted internal investigations in the United States, Asia, Africa, Europe, and Latin America.  She regularly counsels clients on FCPA compliance, assists in developing and conducting FCPA training and compliance programs, and conducts anti-corruption due diligence and risk assessments.  In addition to co-authoring several articles on the FCPA, Ms. Parker is a co-author, with Roger M. Witten, Jay Holtmeier, and Erin Sloane of the firm’s New York office, of a leading treatise in the field, Complying with the Foreign Corrupt Practices Act.  Ms. Parker is ranked for FCPA work in Chambers USA: America's Leading Lawyers in Business.


Patricia M. Byrne (“Trish”) is the VP & Associate General Counsel for International Compliance at BAE Systems Inc.  In addition to managing the International Trade Licensing and Trade Compliance teams, Trish’s work involves policy administration, training on FCPA and anticorruption laws, conducting due diligence on third party business partners, merger and acquisition FCPA diligence, and Offsets compliance.  Trish joined BAE Systems Inc. as Counsel for International and Domestic Compliance in October 2008.  Prior to joining BAE Systems Inc., Trish was a Counsel at WilmerHale, in Washington D.C. where her work focused primarily on FCPA investigations, and on reviewing, creating, and implementing anti-corruption compliance programs for multinational companies.  Trish also has experience with general litigation and securities investigations.  Trish received her JD from the University of California at Berkeley, Boalt Hall School of Law, and she graduated with a BA(Hons I)/LLB from the University of Otago, Dunedin, New Zealand.


Thomas J. Koffer is the Global Head of Anti-Corruption & Economic Sanctions Compliance at Credit Suisse, where he oversees Credit Suisse’s enterprise-wide compliance program addressing the U.S. Foreign Corrupt Practices Act, the UK Bribery Act 2010, and other similar anti-corruption laws.  He also oversees compliance with economic and trade sanctions laws administered by the U.S. Office of Foreign Assets Control and other international regulators.  Previously, Thomas served as counsel at Wilmer Cutler Pickering Hale & Dorr, and as a law clerk for judges on the U.S. Second Circuit Court of Appeals and the U.S. District Court for the Southern District of New York.  Before earning a law degree, Thomas investigated political corruption matters at the New York County District Attorney’s Office.  He also previously served with the U.S. Vice President’s Domestic Policy Office.


Hui Chen is a corporate ethics and compliance leader who served as the first Compliance Counsel Expert at the U.S. Department of Justice from November, 2015 to June, 2017. In that role, she provided expert guidance to federal prosecutors and corporate monitors in evaluating companies’ corporate ethics and compliance programs, including authoring the “Evaluation of Corporate Compliance Programs” documented released in February 2017. She had begun her career as a federal prosecutor in the Department of Justice in Washington DC and New York, then served in senior legal and compliance positions in Microsoft Corporation, Pfizer In., and Standard Chartered Bank, in locations ranging from Munich and Beijing to New York and London. She received her undergraduate degree from the University of California at Berkeley and law degree from the University of California in Los Angeles.


Charles E. Cain is the Chief of the Foreign Corrupt Practices Act Unit within the Securities and Exchange Commission’s Division of Enforcement. He has been in the SEC’s FCPA Unit since its formation in 2010 and with the Division of Enforcement for nineteen years. As the Chief, his roles include oversight of the National FPCA program, coordination with domestic and foreign law enforcement, and supervision of individual investigations. During his tenure with the SEC, he has also been responsible for numerous significant cases in other areas including financial fraud, insider trading, offering fraud, market manipulation, disclosure fraud, and broker dealer practices. Mr. Cain is a graduate of The George Washington University Law School.


As a member of the Firm’s Litigation Group, Aisling O’Shea focuses her practice on criminal defense, government investigations and the Foreign Corrupt Practices Act.

Before joining Sullivan & Cromwell, Ms. O’Shea spent five years as a trial attorney in the Fraud Section of the U.S. Department of Justice’s Criminal Division. Within the Fraud Section, Ms. O’Shea was a member of the Foreign Corrupt Practices Unit. In addition to FCPA matters, she focused on fraud matters in securities and healthcare, as well as investigating and prosecuting other complex economic crimes. She also worked with other federal agencies, including the U.S. Securities and Exchange Commission, FinCEN and the Office of Foreign Assets Control.

Ms. O’Shea often handled active and covert investigations, pre-trial and grand jury proceedings, witness interviews and negotiated plea agreements. For one of her highest-profile matters, she and the case team were awarded the Homeland Security Investigations 2016 Outstanding Financial Investigation. This complex FCPA and money-laundering investigation involved corruption in a state-owned oil company in Venezuela and resulted in multiple guilty pleas and significant judgments.

Ms. O’Shea began her career as an associate at S&C, where she worked on complex financial investigations.