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Steinman & Rodgers LLP provides its clients with a full range of legal services in the Foreign Corrupt Practices Act field. With almost five decades of combined experience in FCPA work, we are conversant in the law, the burgeoning number of settlements and deferred prosecutions, and prevailing industry standards and trends.

We recognize that FCPA compliance is not an academic exercise for our clients. Our clients must mesh their compliance obligations with their overall strategies and the need to get business done. We pride ourselves as being business lawyers. Rather than simply raising red flags, we strive to help our clients navigate through the challenges of cross-border commerce, comply with their legal obligations, and fulfill their business goals.

 

 

FCPA enforcement is at its highest level ever. In a few short years, corporate fines have increased from the tens of millions to the hundreds of millions of dollars, and a record number of individuals are serving prison sentences for FCPA violations. Our attorneys regularly assist our clients in conducting internal investigations when potential or actual problems arise.

We regularly assist our clients in conducting internal investigations around the globe and defending against government enforcement actions. We know that FCPA problems require a swift reaction to ascertain the scope of the matter, stop problematic behavior, protect and review documents and electronic information and evaluate potential exposure. In many cases, we call upon our network of local counsel to help our clients simultaneously address both U.S. and foreign legal issues in an investigation. While the internal review of potential corruption is a serious matter, we are known for our calm, measured and proportionate approach.

When the dust settles following in internal review, we have significant experience in assisting our clients to implement remediation plans to redress issues and to ensure that they do not arise in the future. In the worst case scenarios, we help guide our clients through the process of disclosing misconduct to officials at the Department of Justice and the Securities and Exchange Commission. However, we do not ascribe to the increasingly popular philosophy that all FCPA problems must be disclosed to the enforcement agencies. Rather, we counsel our clients to examine each situation individually, and to weigh the costs and benefits of disclosure on a case-by-case basis. Where it is reasonable to conclude that disclosure would likely lead to a declination, we believe that it is appropriate for companies to address FCPA matters internally, without the pain and expense of the disclosure process.