Anti-Corruption & FCPA

Davis Polk is known for having one of the premier Foreign Corrupt Practices Act (FCPA) practices. For over 30 years, our litigators have represented corporate and individual clients in some of largest and most significant FCPA investigations.

We offer clients a unique platform that combines our experience and leading reputation in FCPA investigations and reviews with an integrated team to support clients around the globe. Our elite global litigation and enforcement practice has extensive experience in advising clients on: 

  • Compliance with the FCPA
  • Acquisition due diligence
  • Internal investigations
  • Governmental investigations and enforcement actions

Our partners have substantial government experience, making us particularly suited to advise on cutting-edge FCPA developments.

  • Former Deputy Assistant Attorneys Generals, who supervised DOJ’s FCPA program
  • Former Director of Enforcement, who supervised the SEC’s anti-corruption practice worldwide
  • Former U.S. Attorney for the Eastern District of Virginia, who led the office in bringing cases related to corruption
  • Former Hong Kong and PRC country representative of TRACE International, who has represented and advised Hong Kong’s ICAC

We have conducted confidential corruption-related investigations and reviews across various industries in over 70 countries. In addition to our involvement in some of the largest DOJ, SEC and international corruption investigations, clients call on us for advice on all facets of FCPA compliance, including designing, developing and conducting intensive training programs.

Davis Polk is pleased to present its DOJ and SEC FCPA Resolution Tracker. The tracker details key characteristics of corporate and individual FCPA resolutions and is available through the links below.

View the 2020 Year-End FCPA Resolution Tracker



View previous resolution trackers:

SEC and CFTC Update

monthly newsletter providing insight into recent developments, key cases, and trends in enforcement at the SEC and CFTC.

CLE Webcasts

Davis Polk partners offer biannual webcasts highlighting U.S. and global anti-corruption enforcement activity, key developments and trends.

Credit Offered: 1.0 CLE Credit(s): CA – General; NY – Professional Practice/Practice Management









Chambers Global – FCPA

Chambers USA – Ranked nationally among U.S. Firms.

    • Davis Polk “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.”
    • Davis Polk is a “[h]ighly regarded FCPA group with strong white-collar credentials…[they have an] impressive portfolio of corporate representations, frequently advising on compliance and enforcement actions.” 
    • Davis Polk has a “robust practice with deep expertise defending clients in high-stakes global FCPA investigations.”
  • Clients say: “They have a great team for FCPA matters," noting the firm's "great understanding of the regulators and international experience.”

Legal 500 U.S. – “The firm, which has a longstanding reputation in the market, is an undisputed leader for FCPA work.” 

Global Investigations Review – GIR 30

    • “Davis Polk & Wardwell’s white-collar and investigations practice is one of the world’s very best, with its partners having worked across the highest levels of government. And that experience shows: they are securing regular declinations for clients.”

Notable Matters

  • Telia Company AB. We represented Telia in the largest FCPA resolution in history involving allegations of employees paid bribes to enter into the Uzbekistan market. The global settlement included resolutions with DOJ, SEC, Dutch Prosecutor and Swedish authorities.
  • Cisco Systems. We represented Cisco in connection with investigations conducted by the SEC and DOJ into potential breaches of the FCPA related to business activities in Russia and elsewhere in the Commonwealth of Independent States. Both the SEC and DOJ declined to bring enforcement actions.
  • AstraZeneca.  We represented AstraZeneca, one of the world’s largest pharmaceutical companies, in an investigation by the SEC and DOJ of the pharmaceutical industry across seven countries, including China. The broad-ranging inquiry, which spanned several years, focused on activities, including sales practices, internal controls, distribution, and interactions with healthcare providers, institutions and government officials.
  • Global Financial Institutions. We represent numerous global financial institutions in connection with U.S. and other regulatory agency inquiries into the hiring of family members of high-ranking foreign officials in China and elsewhere.
  • Global Energy Company. We represented a global construction, energy and industrial services company, operating in more than 40 countries around the world, in connection with a World Bank investigation relating to the company's activities in Bangladesh. After an extensive investigation and advice on remedial efforts, the World Bank and Asian Development Bank both declined to bring charges.
  • Morgan Stanley. We achieved a landmark result for Morgan Stanley in connection with an investigation by DOJ and the SEC into FCPA violations relating to Morgan Stanley’s real estate investing operations in mainland China. The matter resulted in the first-ever public decision not to charge a company based on the quality of its anti-corruption program.
  • Smith & Nephew plc. We represented Smith & Nephew plc and its U.S. subsidiary in connection with the DOJ and SEC settlements of their joint anti-corruption investigation into practices in the medical device industry.
  • IBM Corporation. We represented IBM in a publicly disclosed investigation by DOJ of FCPA issues in several countries, including Poland, Bangladesh, Argentina and Ukraine.
  • BHP Billiton. We advised BHP Billiton, one of the world’s largest mining companies, on investigations into potential FCPA breaches related to previously terminated exploration and development efforts, as well as hospitality provided as part of the company’s sponsorship of the 2008 Beijing Olympics.
  • Telecom Italia. 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.
  • Siemens. We represented Siemens in one of the largest FCPA investigations in U.S. history, which resulted in a landmark settlement with DOJ and the SEC. We also coordinated the company’s global defense to investigations in multiple jurisdictions and a settlement with the World Bank.