Davis Polk has vast experience in conducting internal investigations and navigating through the issues that companies face in this context. We have conducted hundreds of internal investigations over the years, for companies both public and private, large and small. These include investigations in response to such allegations as FCPA violations, money laundering, economic sanctions violations, campaign finance improprieties, insider trading, fraudulent business practices and others. Many of our clients in these matters are Fortune 500 companies, including companies that provide market-leading products and services in the technology, consumer, defense/aerospace and finance industries.

 

• We advised ABN AMRO in connection with an internal investigation and potential litigation relating to a credit facility.
  
  
  
• We conducted an internal investigation on behalf of the Board of Directors of a major fund complex where the Chief Compliance Officer (CCO) resigned alleging issues with the compliance environment and level of support and cooperation that the CCO had received during her tenure. A written Davis Polk report was prepared for the Board of Directors and later provided to the SEC. The SEC took no further action after reading the report.
  
  
  
• We represented an adviser to a fund complex in investigations by, and litigation with, the SEC, the New York State Attorney General’s Office and private plaintiffs over disclosure issues and 12b-1 fees.
  
  
  
• We represent an individual in connection with the Galleon Group insider trading investigation.
  
  
  
• We represent a hedge fund in connection with the SEC Enforcement Division’s insider trading investigation of recent merger transactions.
  
  
  
• We advised Banco Santander Central Hispano, a Spanish bank, on an internal investigation into the foreign exchange trading activities by a former employee.
  
  
  
• We advised the Audit Committee of Collins & Aikman, a Michigan-based manufacturer of car interior products, on an internal investigation of allegations by former executives on bookkeeping issues.
  
  
  
• We advised a Special Committee of the Board of Directors of Bausch & Lomb and conducted an internal investigation with regard to alleged accounting irregularities.
  
  
  
• We conducted an internal investigation at the request of the Legal Committee of the Board of Trustees of the Metropolitan Museum of Art.
  
  
  
• We represented the Audit Committee of Bear Stearns in its investigation into the collapse of two of its sponsored hedge funds.
  
  
  
• We represented committees of independent directors of the boards of C-NET, E*TRADE and KB Home, in their respective investigations into practices for awarding stock options.
  
  
  
• We represented the Audit Committee of the Board of Royal Dutch/Shell in its investigation of the accounting issues relating to recategorization of almost four billion barrels of proved reserves.
  
  
  
• We represented a Special Committee of the Board of JetBlue in its investigation of certain internal matters.
  
  
  
• We represented a Special Committee of the Board of Starwood Hotels & Resorts in an investigation of allegations related to a member of senior management.
  
  
  
• We represented the Audit Committee of the Board of Directors of Stone Energy in connection with an investigation into certain adjustments to oil and gas reserves.
  
  
  
• We represented the Audit Committees of the Boards of Rosetta Resources and Lydall in their investigations of allegations related to members of senior management.
  
  
  
• We represented a Special Committee of the Board of State Farm in its investigation of certain alleged employment and promotion practices that had led to substantial litigation by its agents against the company.