Ann Sultan
Member
Vice Chair, International
Ann Sultan guides companies and executives through complex cross-border internal and government investigations and creating sustainable risk-based corporate compliance programs. Public companies and private organizations turn to Ann for advice on a wide range of enforcement, ethics, and compliance topics, including those related to workplace misconduct (including harassment, discrimination, bullying, and retaliation), the Foreign Corrupt Practices Act (FCPA) and anti-money laundering laws and regulations, due diligence, risk management, Department of Justice (DOJ) and Securities and Exchange Commission (SEC) investigations, and interactions with external auditors in the context of accounting and financial reporting matters.
Ann held a leadership role on the recently-completed Independent Monitorship of Wynn MA, LLC, which focused on human resources issues, including harassment and discrimination.
As a Russian speaker, Ann assists companies doing business in Eastern Europe and Central Asia and individuals who are based in the region.
Ann combines her expertise as external counsel with in-house experience, having been detailed to multinational clients to assist on internal investigation and compliance matters.
Ann is a Certified Compliance and Ethics Professional (CCEP-I) by the Society of Corporate Compliance and Ethics. She is involved in leadership positions with the Anti-Corruption Committees of the International Bar Association and the American Bar Association.
Prior to joining Miller & Chevalier, Ann practiced as a corporate attorney specializing in corporate governance, mergers and acquisitions, and financing at an AmLaw 200 firm. After graduating from Columbia Law School, Ann completed a Postdoctoral Fellowship in Mediation at Columbia Law School.
Representative Engagements
Workplace Misconduct
- For a multinational company, assisted with an investigation into sexual misconduct and code of conduct violations by the CEO and responding to regulator inquiries, which were closed with no action as to our client. Worked with foreign law firm to assess risks of and strategy for potential non-US regulatory action against our client.
- Conducted an investigation into allegations of harassment, bullying, discrimination, and retaliation by the President and COO of an organization, in addition to allegations of government contracts fraud, reporting directly to the Board of Directors. The investigation led to changes in management in addition to significant process improvements at the organization.
- Advised a multinational technology company on the exit of a senior leader found to have violated the company’s code of conduct and misled investigators.
- Served in a leadership role on an Independent Monitor team focusing on human resources issues, including harassment and discrimination, on behalf of a regulatory agency in Massachusetts, for Wynn MA, LLC.
- Represented an executive of a global humanitarian non-profit organization in connection with an investigation related to alleged racial discrimination, harassment, and retaliation.
- On behalf of a global extractives company, investigated allegations of improper behavior by senior regional leadership that included bullying and led to a disintegration of the company's speak up culture.
Anti-Corruption and Other Financial Crimes
- Served as a core team member on a large FCPA internal investigation, which involved the collection of relevant data across a range of nations in Europe and Central Asia, disclosures to the relevant government agencies and external auditor, related remediation efforts, coordination with counsel for board and other jurisdictions, representation of multiple employees in government interviews, and eventual multi-lateral international resolution including a 45 percent reduction from Sentencing Guidelines fine range.
- Represented a Fortune 500 company in an investigation by the SEC, DOJ, and foreign authorities related to potential bribery, internal accounting controls, and books and records violations in connection with its business in an African country. Worked closely with foreign counsel. The matter ended with no action as to our client by any authorities.
- Represented multiple U.S.- and foreign-based individuals in SEC and DOJ proceedings investigating bribery, money laundering, securities fraud, and other financial crimes
- Negotiated a non-prosecution agreement with the DOJ for a European citizen accused of wire fraud
- Advised multinational companies on pre-and post-acquisition due diligence and integration
- Investigated accounting and internal governance, and compliance issues at a non-U.S. headquartered company and its U.S. subsidiary, reporting results to the company's external auditor.
- Investigated allegations of improper payments by employees and a third party of a U.S. company's Ukrainian subsidiary. Representation included reporting to the DOJ and resulted in no action taken against our client, the parent company, and its subsidiary.
- Conducted anti-corruption compliance risk assessments for an international oil company.
Rankings and Recognition
- Legal 500: Dispute Resolution: International Trade, 2021 - 2022
- Who's Who Legal: Investigations - Future Leaders: Partners, 2021 - 2022, 2024
- Washington, DC Super Lawyers®: Rising Star, Criminal Defense: White Collar; International, 2019 - 2022
- Global Investigations Review: 40 Under 40, 2020
- Law360: Rising Star, Compliance, 2020
- International Financial Law Review: Rising Star Awards Americas: White Collar Crime, 2020
- DC Bar Capital Pro Bono Honor Roll, 2017 - 2018
- DC Bar Capital Pro Bono High Honor Roll, 2016, 2020
- Harlan Fiske Stone Scholar, Columbia Law School
Affiliations
- Certified Compliance & Ethics Professional (CCEP-I), Society of Corporate Compliance and Ethics
- Chair, Compliance Subcommittee, Anti-Corruption Committee, International Bar Association
- Member, Steering Committee, Anti-Corruption Committee, Section of International Law, American Bar Association
- Member, Women's White Collar Defense Association
- Board Member, Friends of CEELI Institute
- Leadership Council on Legal Diversity (LCLD) Pathfinder Program, 2018; Fellows Program, 2023
Admissions
State Admissions
- District of Columbia
- Massachusetts
Court Admissions
- United States Court of Appeals for the Sixth Circuit
News and Events
Events
Speaking Engagement
Workplace Misconduct Compliance and Investigations: What Board Members and Senior Leaders Need to Know
Speaking Engagement
SCCE 23rd Annual Compliance & Ethics Institute
Speaking Engagement
International Bar Association 2024 Annual Conference
Speaking Engagement
What Boards of Directors and Senior Leaders Need to Know About Workplace Misconduct Compliance and Investigations
Speaking Engagement
GIR Live: Women in Investigations 2024
Publications
Internal Publication
DOJ Releases Updated Evaluation of Corporate Compliance Programs Guidance
External Publication
The Guide to Compliance – Third Edition: Introduction and U.S. Compliance Requirements Chapter
Internal Publication
FCPA Summer Review 2024
External Publication
Top Five Takeaways on Corruption Perception in Latin America: Insights from Professionals Across the Region
Internal Publication