Our Approach

We are widely recognized as having one of the preeminent Foreign Corrupt Practices Act (FCPA) practices in the United States. Our litigators have represented corporate and individual clients in some the largest and most significant recent FCPA investigations, most recently including our representation of Siemens AG in a global investigation involving corruption allegations brought by regulators and enforcement authorities in several countries. We have unparalleled expertise in advising clients on compliance with the FCPA, conducting internal investigations, and defending clients in governmental investigations and enforcement actions. These matters frequently are international in scope and increasingly involve Davis Polk lawyers working closely with counsel in many other countries.

Notable Matters

  • We represent Siemens AG and are advising it in criminal and regulatory matters in numerous jurisdictions relating to corruption allegations - including advising the company on financial reporting, coordinating its global defense as to non-U.S. investigations, and assisting in the development of enhanced compliance policies and procedures. We acted as counsel in Securities and Exchange Commission (SEC) and U.S. Department of Justice (DOJ) proceedings, and we currently represent Siemens before various multilateral development banks and in civil matters arising from the corruption matter. In coordination with the simultaneous settlement of related German proceedings, we successfully structured a court-approved resolution of all criminal and civil investigations by the DOJ and the SEC.
  • We represent a major financial institution in connection with a publicly disclosed internal investigation into potential FCPA violations in China.
  • We advised a major European telecommunications company in connection with an internal investigation into possible corruption issues.
  • In the past year, we have conducted confidential FCPA-related investigations or reviews for clients in many countries, including Argentina, Brazil, China, Colombia, Indonesia, Mexico, Pakistan, the Philippines and Venezuela. Many of those clients are Fortune 500 companies, including companies that provide market-leading products and services in the technology, consumer, defense/aerospace and finance industries.
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