Our Services

FCPA Compliance, Due Diligence & Counseling

Our lawyers support clients across industries in developing, implementing, and maintaining robust, state-of-the-art compliance programs designed to identify, quantify, and mitigate potential corruption risks in global transactions.  We frequently assist clients with conducting risk assessments of their international operations. We have a long-standing focus on addressing the potential corruption risks arising from international business relationships, including sales representatives, consultants, distributors/resellers, joint venture partners, and offset advisors.  We regularly help our clients with reviewing due diligence materials to identify red flags.  We leverage our experience reviewing potential business relationships to help clients ensure that they identify and mitigate potential risks, as well as keep pace with industry compliance trends.

Investigations & Enforcement Actions

Our lawyers assist clients in formulating and conducting internal investigations around the globe, assessing the results of those investigations to help clients make reasoned decisions about reporting, and defending against government enforcement actions and debarment proceedings. Corruption issues 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. We take a calm, measured, and proportionate approach to internal reviews of potential corruption.  If necessary, we can guide clients through the process of disclosing misconduct to officials at the Department of Justice and the Securities and Exchange Commission.  We also have significant experience assisting our clients to implement remediation plans to redress issues and to ensure that they do not resurface in the future.

Separately, we have provided critical expert witness support for companies in arbitration and facing enforcement efforts involving anti-corruption allegations.

Offset Transactions

Offset plays an increasingly important role in international aerospace and defense sales. Companies are routinely called upon to invest substantial sums of money in the countries that purchase their products and services. Whether an obligation is structured as a direct or indirect offset, suppliers face compliance risks in discharging these requirements.

Steinman & Rodgers offers experience in assisting clients to address applicable legal standards while structuring and fulfilling offset obligations. We conduct due diligence reviews of third-party consultants engaged to identify potential offset partners. We help clients scrutinize individual offset transactions to identify and mitigate risks that funds will be funneled to foreign government officials.

Training

Training is a critical element of a successful FCPA compliance program. Our attorneys provide dynamic presentations that engage participants in training sessions. We conduct training for a wide range of audiences, including boards of directors, C-suite executives, audit committees, sales personnel, accounting and audit staff, legal teams, non-profit organizations, and overseas intermediaries. We do not believe in a one-size-fits-one approach to training, tailoring each presentation to the specific audience. We also regularly help clients design web-based training, and also conduct “train the trainer” sessions that allow our clients to take our training tools to implement their own programs.

Local Counsel Network

Steinman & Rodgers maintains professional and personal relationships with lawyers and local law firms in over ninety countries.  In most cases, we have known and worked with them for many years on a wide range of projects. For our clients, Steinman & Rodgers’ network of local counsel creates convenience, particularly when faced with matters arising simultaneously in numerous jurisdictions. Rather than facing the daunting and time-consuming task of finding counsel in several countries, our clients rely on us to coordinate and manage their projects around the globe through our local counsel network.