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Davis Polk is known for having one of the premier Foreign Corrupt Practices Act (FCPA) practices. For over 25 years, our litigators have represented corporate and individual clients in some of largest and most significant FCPA investigations, including our representation of Siemens AG in a global investigation involving corruption allegations brought by regulators and enforcement authorities in several countries. We have extensive experience in advising clients on compliance with the FCPA, acquisition due diligence, 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. In addition, we have numerous lawyers in our overseas offices, including in London and Asia, who are experienced in conducting FCPA investigations and reviews.
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Awards and Rankings

  • Ranked nationally among U.S. law firms in Chambers USA: Davis Polk’s FCPA Group “impresse[s] the market with its export controls and FCPA expertise... It has been involved in some of the most significant DOJ, SEC and international corruption investigations and advises clients on all facets of FCPA compliance.”

  • According to clients “[t]he attorneys’ efficiency and the uniformly high quality of their work is a major draw.” Chambers USA 2011

Notable Matters

  • We represented Siemens AG in the largest FCPA investigation in U.S. history, which resulted in a landmark settlement with the DOJ and SEC. We also advised on the company’s global defense to investigations in multiple jurisdictions and a settlement with the World Bank.

  • We represent two major financial institutions in connection with the SEC’s industry-wide FCPA review of the Sovereign Wealth Fund business.

  • We represent Morgan Stanley in connection with a publicly disclosed internal investigation into potential FCPA violations in China. 

  • We advised Telecom Italia, a major European telecommunications company, in connection with an SEC inquiry into possible corruption issues. The SEC closed the inquiry without action.

  • We represented a former senior executive of British defense contractor BAE Systems in the much-publicized investigations by the U.S. and U.K. governments into alleged corruption violations by that company. 

  • We represent one of the world’s largest mining companies in a recently disclosed FCPA investigation relating to certain exploration projects in multiple worldwide jurisdictions. 

  • We represent one of several major drug companies in connection with a joint SEC and DOJ anti-corruption investigation into the pharmaceutical industry.
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