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Margaret M. Ayres
Counsel

Ms. Ayres is counsel in Davis Polk’s Washington DC office. She concentrates in U.S. trade and investment laws applicable to cross-border transactions, including the Foreign Corrupt Practices Act (“FCPA”), U.S. economic sanctions, the U.S. anti-boycott laws and laws restricting foreign investment in the U.S. communications, shipping, aviation, nuclear and defense industries. She has advised many companies around the world, including software, pharmaceutical, travel industry, banking and investment banking clients, on the FCPA and related statutes, as well as the other laws just noted.

Her anti-bribery advice has focused on worldwide transnational anti-corruption measures and conventions as well as FCPA enforcement actions and developments. Ms. Ayres has drafted numerous agent agreements, guidelines and compliance codes, tailored to take account of differences in corporate operations, structures and cultures. She has also conducted intensive training programs for U.S. companies and their overseas subsidiaries in many parts of the world, as well as for foreign issuers of U.S. securities.

Contact
  • Washington DC
    901 15th Street, N.W.
    Washington, DC 20005
    P: 202-962-7142
    F: 202-962-7078
Bar Admissions
  • District of Columbia
  • U.S. District Court, District of Columbia
Education
  • B.A., Smith College, 1965
    • cum laude
  • J.D., Yale Law School, 1972

Of Note
  • Has published a number of articles on the FCPA
  • Has been a faculty member for many FCPA seminars in the past eight years, including ABA, ACI, PLI and New York City Bar seminars. Topics have included Developments in the U.S. and International Efforts to Prevent Corruption; Conducting an Effective FCPA (Anti-Corruption) Compliance Assessment; Managing Risk in Third-Party Relationships and Acquisitions; The FCPA Demystified; Managing and Mitigating Risks in Mergers and Acquisitions, Joint Ventures, and Other Third-Party Relationships; International Mergers & Acquisitions: The Need For Enhanced Due Diligence With Respect to Regulatory Compliance; Dealing with Corruption Issues in Commercial Transactions; and Meeting the Challenge of Compliance.

Current Memberships

  • Member of the Board, Washington International Trade Foundation

Past Memberships

  • Vice Chair, Anti-Corruption Initiatives & Compliance Issues Committee, Section of International Law, American Bar Association
  • Vice Chair, Task Force on Corruption, American Bar Association
  • Member, Executive Committee, Yale Law School Association, 1995-1997
Professional History
  • Counsel, 1989-present
  • Associate, 1982-1989