Providing local and cross-border anti-bribery and corruption and anti-money laundering advice
Our global anti-bribery and corruption team has extensive experience of advising clients across industry and sectors in relation to local and cross-border bribery and corruption and money laundering compliance issues, and related internal investigations. This often requires a wider skill-set than simply knowing the law; we also offer broader reputational and crisis management expertise, such as dealing with investor and public relations, insurance and employment issues and the enforcement agencies.
We recognise that the results of an investigation may have material business and reputational impact both for the company and individuals within it. We advise boards and senior management committees on their obligations and responsibilities, corporate governance requirements and fiduciary duties as they arise in the course of investigations and as a matter of best practice.
Best advisors on global anti-bribery and corruption compliance
We have significant experience globally in developing or transforming existing compliance programmes into effective global programmes with embedded processes and cultures. We assist companies with embedding an anti-bribery and corruption compliance culture by developing a workable international framework and providing accessible internal education such as e-learning and webinars, face to face training and internal audit and monitoring programmes.
Assisting with risk assessments and due diligence on new market entry and investments
We assist companies in undertaking anti-bribery and corruption risk assessments, in particular when entering in to an emerging market or contracting with a high-risk third party. We advise on appropriate risk-based due diligence of contractual partners and the inclusions in contracts of appropriate anti-bribery and corruption warranties, indemnities and audit, investigation and termination rights. We have the expertise to advise on the seriousness of the risk and whether or not it can be appropriately mitigated.
Conducting global bribery and corruption investigations
We assist clients to undertake investigations which often involve investigating activities across numerous jurisdictions, requiring compliance with applicable statutory, regulatory and other legal requirements and dealing with various regulators and enforcement agencies. Our approach is to scope the investigation at the outset to ensure that it is proportionate to the issue under investigation, but also to look beyond the investigation itself, to consider the wider impact and its output, including associated risks such as the potential collateral litigation brought by third parties.
Our experience includes advising:
- A potential investors in an oil and gas company on an investigation into the provenance of an oil and gas exploration licence obtained from an African state including payments made to an intermediary with close connections to foreign public officials in relation to the licence;
- A vehicle manufacturing company advising and managing the planning and execution of a systematic anti-corruption investigation in several European jurisdictions;
- A confidential client on an investigation of allegations of employees paying kickbacks to government officials in the Philippines;
- An international telecoms company on allegations of payments made by a joint venture partner to public officials in South America to acquire a licence, including conducting an internal investigation and advising on reporting to enforcement agencies in Europe and the US;
- A global transport corporate on a multi-jurisdictional investigation into allegations of bribery by a local agent in connection with the award of contracts for the operation of transportation systems;
- A majority shareholder of a German electronic retail chain and special auditor on an investigation concerning corruption by members of senior management;
- A UK oil and gas exploration company in relation to an investigation into bribery payments made within Indonesia;
- A major regional food and beverage company an investigation into allegations of corruption within its business in Singapore;
- A European bank on an internal investigation into bribery and corruption by intermediaries and reporting suspected corruption and money laundering to the Serious Fraud Office, National Crime Agency and Financial Conduct Authority and equivalent authorities in Spain; and
- A UK oil and gas exploration and production company in relation to criminal and civil investigations in the UK and US concerning allegations of large-scale bribery and corruption
