Anti-Corruption & the Foreign Corrupt Practices Act (FCPA)

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RK&O lawyers have deep expertise in all facets of FCPA and related anti-corruption laws. Our comprehensive practice ranges from full-scale internal and government investigations and enforcement defense to transactional due diligence and compliance and internal controls reviews. At our core, we drive solutions and are adept at tackling each unique challenge.

Our practice extends well beyond typical compliance and investigation issues, often intersecting with related laws involving domestic corruption, bribery, money laundering and economic sanctions. Our extensive experience in each of these areas informs the others, allowing us to represent our clients across a full complement of cross-border anti-corruption issues. more +

We have built our blue chip reputation on the results we have achieved for our clients. Over the past 25 years we have discreetly conducted internal investigations, defended clients in enforcement matters, overseen due diligence projects and developed compliance programs for many of the world’s most respected companies, investment funds and boards of directors.

All of our FCPA lawyers, from junior associate to senior partner, have established practical experience in the technical aspects of the FCPA and how it is currently enforced. Our team provides multi-level counseling in connection with the most important and relevant issues of the day, providing clients a thorough understanding of current enforcement trends, the market effects of FCPA compliance and recommended risk mitigation strategies.

RK&O maintains a truly international anti-corruption practice, representing clients before various regulatory and enforcement agencies around the globe. Our well-earned standing with these regulators enables us to guide clients through complex multinational, parallel enforcement matters in regional hot spots including:

  • Africa (North & Sub-Saharan)
  • China
  • East Asia
  • Europe
  • India
  • Latin America
  • The Middle East
  • Russia


  • Conducted an internal investigation on behalf of a multinational financial institution relating to anti-corruption and internal controls issues arising at a Latin American affiliate and advised client regarding disclosure of information to local and U.S. regulators.
  • Conducted an FCPA investigation and evaluation of compliance system and internal controls on behalf of the audit committee of a publicly listed global asset manager in connection with issues arising in North and Sub-Saharan Africa and Europe.  Interacted with the U.S. DOJ and SEC.
  • Represented a Latin American sports marketing and production company in connection with a wide-ranging government investigation of alleged FIFA corruption.
  • Represented senior employees of a global investment bank with respect to an FCPA investigation conducted by DOJ and SEC into hiring practices in China.
  • Advised a multi-billion dollar investment fund with respect to FCPA compliance process and transactional due diligence undertaken by a portfolio company doing business with a Venezuelan government entity.
  • Oversaw an FCPA compliance audit of a Swedish construction equipment company doing business in Russia and Eurasia.
  • Conducted anti-corruption due diligence and advised a multi-billion dollar investment fund with respect to portfolio company transactions in Brazil, Kazakhstan, Mongolia, Vietnam, Indonesia and Russia.
  • Represented the former chief executive officer of Direct Access Partners LLC with respect to FCPA prosecution in the SDNY.
  • Counseled a U.S. financing company with respect to FCPA due diligence and compliance considerations related to contemplated financing transaction involving a Venezuelan government entity.
  • Represented a prominent international law firm in connection with allegations by one of its clients that a partner in one of its foreign offices had engaged in conduct that violated the FCPA.
  • Represented the chief investment officer of a boutique investment bank in connection with SEC and criminal investigations into alleged FCPA violations and related fraud.
  • Advised multi-billion dollar investment funds on anti-corruption and anti-money laundering risk analysis and due diligence with respect to investments in Indian telecom, power and infrastructure and financial services acquisitions.