04.01.2021
News
Timothy O'Toole, Member at Miller & Chevalier Chartered, discussed how attention has turned to how President Biden will approach the issue of economic and trade sanctions policies – specificall
- Conducted an internal investigation of a client’s operations in Nigeria and Kazakhstan in response to a U.S. Department of Justice (DOJ) notification of an inquiry to our client. The investigation expanded to involve dozens of interviews in multiple countries and the collection of millions of pages of hard copy and electronic data.
- Assisted two major multinational companies with Foreign Corrupt Practice Act (FCPA) due diligence and related investigations regarding two separate multi-million dollar acquisitions, necessitating multidisciplinary teams in simultaneous reviews worldwide, with eventual disclosure and successful resolution of discovered FCPA issues.
- Conducted multiple inquiries into anti-corruption matters on behalf of a large company in an oil-related industry. Investigations were conducted in Libya, Oman, Vietnam, Indonesia, Malaysia, Egypt, Nigeria, China, Uzbekistan, Russia, Algeria, Dubai, Kazakhstan, India, Singapore, Brazil, Argentina, and other countries. The investigations resulted in no new sanctions or enforcement actions against the company and satisfactory evaluations of the company’s compliance and enforcement protocols.
- Created a protocol for a client to govern all its internal investigations, including matters involving allegations related to the FCPA and other anti-bribery laws, export controls, accounting and financial fraud, and antitrust violations and will provide on-going advice with respect to investigations conducted under the protocol.
- Conducted an investigation in India on behalf of a healthcare services provider in the midst of being acquired. The investigation focused on internal controls, government contracting, and tax issues identified as the deal was closing. The investigation was completed to the satisfaction of the acquiring company, and the deal closed successfully.
- Engaged to conduct a multinational review of a company’s use of a global freight forwarder and customs broker. Firm teams made multiple trips to Kazakhstan, Nigeria, and Europe, conducting dozens of interviews and collecting hundreds of thousands of documents related to the investigation. The matter was resolved with no action against the client.
- Conducted multiple internal investigations on behalf of large U.S. information technology company into allegations of improper payments to government officials by company subsidiaries in Korea, Brazil, Mexico, and South Africa.
- Investigated possible violations of the Syria embargo on behalf of a large multinational healthcare company.
- Represented the Audit Committee of a private large resource extraction company in conducting an internal investigation of the company’s activities in a country in West Africa. The investigation expanded to include a review of operations in another half dozen West African countries, including extensive document review and interviews with all third parties retained by the company to assist with business development, including several no longer working for the company. This effort involved coordination throughout with current and potential outside investors and auditors.
- Conducted an internal factual investigation on behalf of a large manufacturer into alleged export control violations by one of its subsidiaries in connection with the shipment of satellite telecommunications equipment to a foreign government’s military.
- Conducted an internal investigation in the UAE on behalf of a Fortune 500 manufacturer of industrial pumps, valves, and seals involving allegations of corrupt payments by third-party agents.
- Conducted internal investigations in response to allegations that a company and its U.S. and foreign-based personnel and advisors planned and implemented transactions in multiple countries with the intention of defrauding foreign tax authorities.
- Conducted an internal FCPA investigation on behalf of a client that involved the review and production of pertinent documentation relating to two projects in Southeast Asia, as well as on-site interviews in the company’s global locations and an assessment of the company’s potential FCPA liability.
- Conducted an internal investigation on behalf of a client of possible violations of U.S. sanctions and embargoes, as well as provided an assessment of company processes and procedures for compliance.
- Conducted an internal investigation on behalf of a large law firm regarding alleged sexual harassment by a top manager.