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The Foreign Corrupt Practices Act and International Anti-Corruption Developments 2013

Speaker(s): Alexandra A. Wrage, Alistaire Bambach, Brian L. Whisler, Charles E. Cain, Cheryl J. Scarboro, Christopher J. Cummings, Claudius O. Sokenu, Danforth Newcomb, David N. Lawrence, F. Joseph Warin, Gina Saviola, Glenn T. Ware, Greg D. Andres, Greta Lichtenbaum, Gustavo Carvajal Isunza, Howard O. Weissman, J. David Fielder, Jason A. Jones, Jordan A. Thomas, Kathryn Cameron Atkinson, Kenneth G. Yormark, Laurence A. Urgenson, Lucinda A. Low, Lynn A. Neils, Mark Morrison, Mark F. Mendelsohn, Martin J. Weinstein, Mary R. Nina Henderson, Peter B. Clark, Raja Chatterjee, Richard W. Grime, Roger M. Witten, Sarah Z. Erickson, Steven A Tyrrell, Susan M. Ringler, Thomas McCarthy, Jr., Timothy L. Dickinson
Recorded on: May. 2, 2013
PLI Program #: 41921

Danforth Newcomb founded the anti-corruption practice at Shearman & Sterling LLP. His practice includes criminal and regulatory proceedings, internal investigations and compliance programs in Europe, Latin America, the Middle East, Asia and CIS countries.  He has conducted many multi-jurisdictional investigations including in Libya, Angola, Bonny Island Nigeria, China and Venezuela and acted as a DOJ & SEC sanctioned Independent Monitor in an Oil For Food prosecution and as a UN approved expert on compliance and ethics.   He also advises on Anti-Money Laundering, Economic Sanctions and sovereign immunity matters. Mr. Newcomb is the founding editor of the Shearman & Sterling FCPA Digest. 

Roger M. Witten, a partner at WilmerHale in New York, has for many years been one of the recognized leaders of the FCPA bar. He leads WilmerHale's 45-lawyer FCPA team, which regularly counsels well over 50 major US and non-US companies and typically has 20 enforcement matters pending before the DOJ and SEC at any one time. Mr. Witten has deep FCPA compliance counseling experience, has supervised numerous FCPA risk assessments, has broad experience providing FCPA counsel in the mergers and acquisitions context, has conducted internal investigations for companies, and has represented companies and individuals at the DOJ and the SEC in numerous publicly disclosed and other matters.  Mr. Witten is the original author, and now co-author with his partners Kimberly Parker and Jay Holtmeier, of the leading treatise, Complying with the Foreign Corrupt Practices Act. Mr. Witten has been named to numerous published "best lawyer" lists. He is a member of the District of Columbia and New York bars. Mr. Witten graduated from Dartmouth College and Harvard Law School. He clerked for The Hon. Harrison L. Winter on the US Court of Appeals for the Fourth Circuit and thereafter served as an Assistant Special Prosecutor in the Watergate Special Prosecution Force. 

He has distinguished himself as an outstanding FCPA practitioner, . . . he has a terrific boardroom presence and a practical approach to dealing with issues and governments around the world." –Chambers Global 2015

Larry Urgenson is a co-leader of the firms' Global Anti-Corruption & FCPA practice. Larry is widely recognized as one of the preeminent FCPA authorities in the United States. He has represented corporate and individual clients in FCPA and anti-corruption matters worldwide for nearly four decades. As noted in Chambers, Larry is "a brilliant lawyer and a leading light at the FCPA Bar." (Chambers USA 2016). He "is highly esteemed for his FCPA practice, which includes advising on statutory compliance and corporate representation in government investigations" (USA 2015), is "known for his experience in high-stakes investigations" (USA 2013) and "offers incredible knowledge in the FCPA area . . . he has great judgment" (USA 2012). Clients praise Larry and state that, "There simply isn't a more client-sensitive strategist out there" (Chambers Global 2016).

Larry was named Benchmark Litigation Star in 2014, 2015, 2016 and 2017. He was also recognized nationally as one of 8 FCPA Masters at the first annual Main Justice Best FCPA Lawyers Client Service Awards in 2013. Additionally, he is a sought-after writer and speaker on white collar matters and is currently the Chairman of the Board of Editors of the Business Crimes Bulletin.

Prior to joining private practice, Larry held key leadership positions at the US Department of Justice (DOJ). As the DOJ's Acting Deputy Assistant Attorney General, he primarily supervised the Fraud Section, General Litigation and Legal Advice Section, and Office of Policy and Management Analysis. Additionally, he testified before various congressional committees regarding the Department's white collar crime initiatives. He also served as the DOJ's Chief of the Fraud Section for the Criminal Division, where he advised US Attorneys on white collar crime issues, supervised the prosecution of bank, securities, and defense procurement frauds, and oversaw the FCPA Unit and the Defense Procurement Fraud Unit. Earlier in his career, Larry served as a Chief Assistant US Attorney for the Eastern District of New York. Larry received the Attorney General's Award for Distinguished Service and the Edmund J. Randolph award for Outstanding Service.

David Lawrence is a Managing Director and an Associate General Counsel. He is the global head of the Business Intelligence Group, which is comprised of a number of attorneys, former government and regulatory officials, and analysts located in the United States, United Kingdom and Asia. The group has global responsibility for a wide range of regulatory and due diligence matters. In this capacity, David provides coverage for the Investment Banking, Fixed Income, Merchant Banking, Equities and Asset Management divisions.

David serves on the firm's Commitments, Capital, Credit Markets, Diverse Business Engagement, and Private Equities Group Committees, and regularly advises a number of the firm's investment committees. He is also an observer of the Middle Market Loan Committee for Goldman Sachs Bank USA and serves as senior advisor to the Legal, Global Compliance, and Internal Audit (LCA) Black Network. David joined Goldman Sachs in 1993 and was named managing director in 1999.

Prior to joining the firm, David was an assistant United States attorney for the United States Attorney's Office, Southern District of New York for approximately ten years. During his tenure, he served as the deputy chief of the Criminal Division and chief of the Public Corruption and General Crimes Units.

David serves on the Board of Directors of John Jay College of Criminal Justice.

David helped establish Regulatory Data Corp (RDC) - a data and technology risk-management company, focused on corporate compliance and reporting solutions to such issues as money laundering, fraud, government corruption and terrorism financing.

David earned a JD from New York University in 1980 and a BA, magna cum laude, from Brandeis University in 1975.

F. Joseph Warin is chair of the Washington, D.C. Office’s Litigation Department, which consists of over 125 attorneys.  Mr. Warin also serves as co-chair of the firm's White Collar Defense and Investigations Practice Group.  He served as Assistant United States Attorney in Washington, D.C. from 1976-83.  In that capacity, Mr. Warin was awarded a Special Achievement award by the Attorney General.  As a prosecutor, he tried more than 50 jury trials.

Mr. Warin's areas of expertise include white collar crime and securities enforcement – including Foreign Corrupt Practices Act investigations, False Claims Act cases, special committee representations, compliance counseling and complex class action civil litigation.  Mr. Warin has handled cases in more than 35 states.  His clients have included corporations, officers, directors and professionals in regulatory, investigative and trial matters.  These representations have involved federal regulatory inquiries, criminal investigations and Congressional hearings.  Recently, Mr. Warin successfully argued motions to dismiss in securities and consumer protection class actions in the Southern District of New York and the District of Columbia.

Mr. Warin’s civil practice includes representation of clients in complex litigation in federal courts and international arbitrations.  He has tried 10b-5 securities and RICO claim lawsuits, hostile takeovers, and commercial disputes.  Mr. Warin has handled numerous class action cases and is currently defending class actions in several district courts including the Southern District of New York, District of Columbia, Eastern District of Missouri and Northern District of California.  These representations include investment banking firms, Big 4 accounting firms, broker-dealers and hedge funds.

For many years, Mr. Warin has been hired by audit committees or special committees of public companies to conduct investigations into allegations of wrongdoing.  These investigations have been in a wide variety of industries including energy, oil services, healthcare, and telecommunications.

Mr. Warin has conducted FCPA investigations relating to business in 35 countries, including, Argentina, Austria, Bangladesh, Brazil, China, Croatia, Dubai/UAE, France, Germany, Great Britain, India, Iran, Iraq, Italy, Jordan, Kazakhstan, Korea, Lebanon, Libya, Mexico, Nigeria, Norway, Panama, Peru, Philippines, Poland, Qatar, Russia and Saudi Arabia, South Africa, and Yemen.  In connection with these investigations, Mr. Warin has provided advice to general counsels and senior management regarding company practices, enhancements to compliance programs, disciplinary action for company employees and remedial measures for improving compliance.  Some investigations have also prompted voluntary disclosures to the SEC and the Department of Justice, and Mr. Warin handled the Department of Justice and SEC investigations.

Significant Representations include:

  • Defended executives of a top technology company and obtained dismissal of a derivative lawsuit alleging options backdating.
  • Defended large telecommunications company in a criminal investigation conducted by Southern District of New York U.S. Attorney’s Office and achieved a declination of prosecution.
  • Successfully led as FCPA counsel for first non-US compliance monitor in connection with largest ever FCPA settlement.
  • Represented the Audit Committee of a $2 billion hospital chain against allegations of financial misrepresentations.Convinced the SEC and U.S. Attorney’s Office not to take any enforcement actions against client.
  • Represented the Audit Committee of Fortune 100 energy company relating to allegations of earnings management.
  • Represented the largest truck-stop company in the United States in an antitrust case and obtained a $49.5 million settlement in favor of the client within two weeks of trial.
  • Defended the president of a hardware supply company in a criminal price fixing case.The jury acquitted our client after a three week trial in St. Louis, Missouri.
  • Recently concluded serving as FCPA compliance monitor pursuant to a deferred prosecution agreement with Securities Exchange Commission and Department of Justice.
  • Obtained dismissal of numerous lawsuits brought against the largest securities self-regulatory organization during course of almost 20 years.

Mr. Warin is one of only ten lawyers in the United States with Chambers rankings in five categories.  He received the Chambers USA Award for Excellence in 2014 in the category of Litigation: White Collar Crime & Government Investigations.  The Excellence awards are given to those who “have excelled above all others in the U.S. legal market over the period 2013-14.” Mr. Warin was honored by Who’s Who Legal for a second year in a row as its 2015 Investigative Lawyer of the Year. Winners are the “most widely recognized for their achievements by the global legal market” as determined by private practitioners and in-house counsel.  In 2016, Who’s Who Legal and Global Investigations Review also name Mr. Warin to their list of World’s Ten-Most Highly Regarded Investigations Lawyers. He has been listed in The Best Lawyers in America® every year from 2006 – 2016 for White Collar Criminal Defense. Best Lawyers® also named Mr. Warin 2016 Lawyer of the Year for White Collar Criminal Defense in the District of Columbia.  In 2016, he was named among the Lawdragon 500 Leading Lawyers in America. From 2015-2017, he has been selected by Chambers and Partners Latin America as a top tier lawyer, Latin America-wide, in Fraud & Corporate Investigations. Chambers Global 2016 ranked Mr. Warin as a top attorney for USA – FCPA. In 2016 Chambers USA: America's Leading Lawyers for Business selected Mr. Warin as a Leading Lawyer in the areas of Securities Regulation Enforcement, Securities, and Litigation: FCPA in the nation. He was also ranked as a Leading Lawyer in the areas of Securities Litigation and White Collar Crime and Government Investigations in the District of Columbia. He was selected as a 2015 Top Lawyer for Criminal Defense by Washingtonian magazine. U.S. Legal 500 named Mr. Warin a 2015 Leading Lawyer for White Collar Criminal Defense Litigation. Benchmark Litigation has recognized him a U.S. White Collar Crime Litigator Star for three consecutive years (2013-2015).  In 2013, Mr. Warin was awarded the Best FCPA Client Service Award by Main Justice.  He was also named to the publication’s FCPA Masters list.  In 2011, Mr. Warin was named a white collar law MVP by Law360.  Mr. Warin was named a Special Prosecutor by the District of Columbia Superior Court in 1988.

Mr. Warin graduated in 1975 from the Georgetown University Law Center, where he was Editor of Law and Policy in International Business.  He received his Bachelor of Arts degree cum laude from Creighton University in 1972, where he was student body president.  After graduation he served as a law clerk for United States District Court Judge J. Calvitt Clarke, in the Eastern District of Virginia.  Mr. Warin has been a member of the American Bar Association's White Collar Criminal Law Committee since 1988 and served as president of the Assistant United States Attorneys Association.  Mr. Warin has been selected to serve on insurance company panels for securities class actions.  He is a member of the Board of Directors of the Washington Lawyers Committee for Civil Rights.

Gina Saviola is counsel in Mayer Brown's Los Angeles office and a member of the Litigation & Dispute Resolution practice. Gina’s practice focuses on FCPA/anti-corruption-related matters, internal investigations and corporate compliance programs. Before joining the firm, Gina was Senior Counsel - Compliance at Occidental Petroleum Corporation for over eight years. She designed, implemented, and monitored the company’s global compliance program, with a particular emphasis on the company’s operations in the Middle East/North Africa, South America and Asia. Gina responsibilities included advising management and the international legal team on risks associated with business transactions and related activity, such as with providing travel or hospitality to non-U.S. government officials , and ways to mitigate those risks. Gina implemented a company-wide third-party due diligence program, revised company policies and procedures, and trained senior management and employees worldwide on the Code of Business Conduct and laws related to anti-corruption and international trade. Gina has significant experience conducting internal investigations, including those involving whistleblower and FCPA-related claims.

Before joining Occidental, Gina was an attorney in the enforcement division of the Securities and Exchange Commission, where she handled a variety of investigations, including into insider trading and market manipulation. Prior to that, Gina was a white collar lawyer in private practice. She handled government investigations, and worked on cases involving bribery, RICO, bank-fraud and money laundering.

Areas of Focus


  • Duke University, BA
  • University of Virginia School of Law, JD


  • California

Glenn T. Ware, Esq. is a Principal/Practice Group Leader at PricewaterhouseCoopers LLP (PwC) and leads the Anti-Corruption & Corporate Intelligence Practice for the U.S. firm.  He also founded PwC’s Anti-Corruption Centre of Excellence – the first of its kind private sector organization dedicated to collecting and promulgating best practices in anti-corruption for the public and private sectors. For clients, he directs a diverse group of over 50 interdisciplinary investigative, forensic, technology, and intelligence professionals that offer the full spectrum of anti-corruption services across all business sectors – both public and private. Mr. Ware is an international lawyer by training. Prior to coming to PwC, he served as the Chief Investigative Counsellor to the President of the World Bank Group where he was a chief architect and directed the anti-corruption investigative function across the entire Bank portfolio. While at the Bank, he ran the Africa Investigative Unit for five years before being promoted to Chief Counsellor. He has lived and worked extensively overseas in Africa, Eastern Europe, the Middle East, Europe and Latin America, assisting private and public sector clients navigate the complex business, ethics and legal challenges in emerging and post conflict markets. He led the establishment of PwC's office in Iraq, and established and led the PwC response team for President Bill Clinton following the devastating earthquake in Haiti to ensure money was used for its intended purposes.

Mr. Ware serves a variety of industry sectors across the globe - addressing a full range of corruption challenges. He is a “board room level advisor” to these companies in helping them address a variety of complex compliance and regulatory challenges. On top of Mr. Ware’s recognized anti-corruption expertise, he has deep experience in international and national security matters following 26 years of government experience as a senior Navy Officer with the Office of Judge Advocate General. He holds an active top secret security clearance and sits on the leadership steering committee of PwC’s Threat Management Groups and has worked for various U.S. and foreign government agencies. Mr. Ware has been retained by former and current heads of State, a Nobel Prize winner and current and former cabinet level officials in the United States and abroad.  

Mr. Ware has lectured at professional and academic forums, including the American Bar Association, International Bar Association, Harvard Law School, Georgetown Law School, the Joint Vienna Institute, U.S. State Department, the Pentagon, the EU, OECD, The World Bank Group, Inter-American Development Bank, Naval War College, National War College, Air War College, Fletcher School of Law and Diplomacy, J.F. Kennedy School of Government, and numerous institutions and professional forums around the world. 

Mr. Ware holds an LLM from Harvard Law School. He is extensively published and quoted as an authority in the media in the areas of fraud and anti-corruption, corporate intelligence, national security, and international governance. He is a member of the ABA National Security Law and International Law sections. He sits on the World Economic Forum's Task Force for Anti-Corruption (PACI), Transparency International USA's Corporate Counsel Forum, and was recently selected by the OECD as a participant for their site inspection of the United States compliance with the OECD Convention against Corruption. In addition to Haiti, Mr. Ware spends a considerable amount of time in Iraq advising the Kurdistan Regional Government on governance issues.

Greg Andres returned to Davis Polk after more than 12 years as a federal prosecutor in both New York and Washington, D.C.  Most recently, he served as a Deputy Assistant Attorney General in the Criminal Division at the Department of Justice.  In that capacity, he supervised many of the Department's most significant white-collar prosecutions, including the Foreign Corrupt Practices Act (FCPA) cases nationwide. He has represented the Department before Congress on various issues, testifying before both houses. From 2007 to 2010, Mr. Andres served as Chief of the Criminal Division in the U.S. Attorney's Office for the Eastern District of New York, where he supervised more than 100 federal prosecutors in a wide range of investigations and prosecutions. He has tried and supervised a variety of high-profile cases involving financial fraud, organized crime and terrorism offenses. Mr. Andres is the recipient of numerous awards in the legal profession, including: The Attorney General's Distinguished Service Award (2008), the Department of Justice Director's Award (2003, 2005, 2010) and the Henry L. Stimson Medal (awarded by the New York City Bar Association). In 2005, the National Law Journal named Mr. Andres to the "Top 40 Under 40" list.

Gustavo Carvajal Isunza, Bilingual attorney with extensive experience in the fields of administrative law in particular in matters related to the (i) environment, and (ii) anti-corruption.

Professional Experience

SOLÓRZANO, CARVAJAL, GONZÁLEZ & PÉREZ CORREA, S.C., Mexico City                  1995-2013

  • Represented Metalclad Corporation, a U.S. public company, in its successful Investor-State Arbitration vis a vis the United Mexican States related to the construction and operation of a hazardous waste lanfill. Offered as expert witness by the Investor and called by Respondent for Direct and Cross Examination during Oral Hearing.
  • Represents Abengoa, a Spanish public company in its ongoing Investor-State Arbitration vis a vis Mexico related to the closure of environmental projects in Hidalgo. Acts as lead counsel.
  • Represents the Commission for Environmental Cooperation, an international entity created by the NAFTA, providing consulting services regarding environmental matters that have been raised to their attention by the NAFTA Parties or nationals of the NAFTA Parties.
  • Represents Carrix/Goldman Sachs in the permitting of their Port Terminal in Tuxpan, Veracruz.
  • Advices several Fortune 500 companies in anti-corruption policy and law in Mexico.
  • Represents the firm in all TRACE activities. Solcargo is TRACE´s partner firm in Mexico.
  • Represents the National Water Commission (Conagua) in a multi million litigation against Carlos Slim´s companies (Grupo Carso) in connection with the construction of the Tunel Emisor Oriente.
  • Represents the Federal Commission of Electricity (CFE) in several arbitrations against independent power producers and other contractors.
  • Advices Monsanto, the world leading company dedicated to sustainable agriculture, in their business operations in Mexico.
  • Represents several UK based Companies, among others, Eco-Securities, Ener-G and Biogas Technology Ltd. in matters related to energy and CDM projects,
  • Retained by the Federal Government, both by the Executive and Legislative Branches, to draft legislation on wastes, water, climate change, anti-corruption, and air pollution.

MINISTRY OF FISHERIES, Mexico City                                                                            
1991-1992; 1994
Chief of Staff for the Minister


HARVARD UNIVERSITY, United States of America    
Master in Public Policy, 1994

Bachelor in Law, with honors, 1991

Academic Activities

Administrative Law Professor at the ITAM, UNAM and the Universidad Panamericana, 1994-2013

Howard O. Weissman is Vice President and Associate General Counsel-International for Lockheed Martin Corporation where he is responsible for providing international legal advice to all elements of the Corporation, including its international field offices, foreign subsidiaries and international joint venture companies.  Mr. Weissman has specific expertise with U.S. laws and regulations directly impacting international business operations such as the FCPA and U.S. antiboycott laws, as well as the International Traffic in Arms Regulations and Export Administration Regulations. Prior to joining Martin Marietta in 1988, Mr. Weissman held international legal positions at the Communications Satellite Corporation (COMSAT) in Washington, D.C., as well as two international law firms. 


J. David Fielder joined INT as the Manager of External Investigations in December 2011. His prior experience includes two years as the Assistant Inspector General for Investigations at the U.S. Securities and Exchange Commission (SEC) where he supervised investigations of the SEC's activities in connection with the Madoff and Stanford Ponzi schemes, and several other matters. He also served at the SEC for several years as a Branch Chief and senior counsel in the Division of Enforcement where he led key parts of the government's case against Enron. In addition to his experience at the SEC, Mr. Fielder was a partner in the Washington, D.C. office of Haynes and Boone, LLP, and Special Assistant Counsel to the President of the United States. He received his B.A. magna cum laude from Washington University in 1987, a master's in hydrogeology/environmental geology from Pennsylvania State University in 1989, and his J.D. from the University of Michigan in 1992.

Jason Jones is an Assistant Chief in the FCPA Unit of the Fraud Section. Prior to joining the Criminal Division, Jason was Chief of the Violent Crimes and Terrorism Section in the U.S. Attorney's Office for the Eastern District of New York, supervising some of the most successful complex racketeering and international terrorism prosecutions in the country. 

Jason has prosecuted and supervised dozens of complex federal cases. Among several other matters, Jason secured convictions against terrorists who plotted to blow up JFK Airport; corporate executives who perpetrated a $2.2 billion securities fraud; and dozens of violent gang members, including two death penalty trials.

Jason's experience also includes the prosecution of a wide range of other federal crimes, including the Foreign Corrupt Practices Act, money laundering, tax fraud, narcotics and firearms trafficking, child pornography, immigration violations and counterfeiting. Jason also participated in the investigation of international terrorists held at Guantanamo Bay, Cuba.

Jason has been the recipient of the Attorney General's Award for Excellence in Furthering the Interests of U.S. National Security, the Federal Law Enforcement Foundation's Federal Prosecution Award, and the U.S. Attorney's Office Award for Excellence in Criminal Litigation.

Jordan A. Thomas is the Chair of the Whistleblower Representation Practice at Labaton Sucharow, which is the first and only national practice that is exclusively devoted to the representation of whistleblowers with information on violations of the federal securities laws.  Jordan is widely regarded as one of the top SEC Whistleblower advocates.  To date, he has won the fourth largest SEC Whistleblower award for a client, over $17 million. He also successfully represented the first officer of a public company to win an SEC whistleblower award, the first SEC Whistleblower to receive criminal immunity and the first SEC whistleblower to receive an award because his company retaliated against him.  Among other high-profile successes, his clients are responsible for the recent $307 million JPMorgan and $415 million Merrill Lynch SEC settlements, their applications for awards are pending.

Prior to joining Labaton Sucharow, he served as a Trial Attorney at the Department of Justices and an Assistant Director in the Division of Enforcement at the SEC.   During his tenure at the Commission, he had a leadership role in the development of the SEC Whistleblower Program and was assigned to many of its highest-profile matters such as those involving Enron, Fannie Mae, UBS, and Citigroup. His cases have resulted in monetary relief for harmed investors in excess of $35 billion.

Kathryn Cameron Atkinson is the Chair of the International Department and a member of the firm’s Executive Committee. Her practice focuses on international corporate compliance, including, in particular, the Foreign Corrupt Practices Act (FCPA), as well as export controls and economic sanctions, and anti-money laundering laws. She advises clients on corruption issues around the world. This advice has included compliance with the FCPA and related laws and international treaties in a wide variety of contexts, including transactional counseling, formal opinions, internal investigations, enforcement actions by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) and resulting monitorships, as well as commercial litigation raising improper payment issues. Ms. Atkinson served as the government-appointed Independent Compliance Monitor for KBR, Inc. in an FCPA matter settled with the DOJ and SEC. She was a member of the original Transparency International task force that developed a compliance toolkit for small and medium-sized entities. She co-produced, with Homer E. Moyer, Jr., "Comply But Compete," a versatile, video-based FCPA training program.

On the compliance side of the practice, Ms. Atkinson focuses in particular on the design and implementation of custom-tailored international regulatory compliance programs for large and small companies in a wide range of industries.  Her compliance practice includes performing compliance due diligence in mergers and acquisitions, designing and performing compliance audits and assessments, training company personnel and third parties, and working with companies to design tailored safeguards in complex business transactions and relationships with third parties.


Anti-Money Laundering

Business and Human Rights

Export Controls & Economic Sanctions

FCPA & International Anti-Corruption

Global Compliance & Risk Management

Internal Investigations

White Collar Defense


J.D., Cornell Law School, 1992

B.A., Johns Hopkins University, Departmental Honors, 1989

Kenneth Yormark is a Managing Director in Grant Thornton’s Forensic and Valuation Services Practice. Mr. Yormark focuses his practice on accounting issues, forensic accounting, financial investigations, securities litigation, and anti-corruption risk assessments. He works with management at major corporations, noted law firms, and government agencies primarily in regard to internal investigations, accounting related litigation matters, and anti-corruption/Foreign Corrupt Practices Act (FCPA) issues in both reactive and proactive environments. He has testified in deposition and at trial in Federal and Bankruptcy courts.

Mr. Yormark is an Adjunct Professor at Georgetown University Law Center where he teaches “Accounting for Lawyers”. He is also a faculty member of the Practicing Law Institute and an adjunct faculty member of the Association of Certified Fraud Examiners.


Mr. Yormark has more than 30 years of experience in the areas of forensic and investigative services, having managed and conducted numerous complex, often high-profile securities fraud, anti-corruption/FCPA and Ponzi scheme investigations involving public and private companies in all industries around the globe. Prior to joining Grant Thornton, Mr. Yormark was a Managing Director and leader of a major consulting firm’s New York Forensic Accounting Practice.  As Managing Director of another firm’s Business Risk Practice, he served as national leader of financial investigations and anti-fraud initiatives. He was Director of Forensic and Investigative services at a Big 4 firm and a Director in the Forensic Accounting Practice of a global corporate investigations firm.

Professional memberships

  • American Institute of Certified Public Accountants
  • Association of Certified Fraud Examiners
  • New York State Society of Certified Public Accountants
  • Member, ABA Section of Business Law
  • Partner to the ABA Litigation Section – Business Torts and Unfair Competition Committee
  • Past partner to the ABA Litigation Section – Criminal Investigations and Access to Justice and Children’s Rights Committees
  • New York Lawyers for Public Interest, Committee Member
  • Make-A-Wish Foundation
  • Circle of Friends


  • Bachelor of Science degree, from Queens College and Graduate Studies from New York University.

Nina Henderson is a Director of CNO Financial Group (Bankers Life & Casualty, Washington National, and Colonial Penn insurance companies) Audit/Risk and Investment committees and a Director of Walter Energy Inc. (Metallurgical coal producer for the global steel industry in Asia, South American and Europe.  She is a former Director of AXA Financial Inc, The Equitable Companies Audit, Investment, Finance/Risk; Del Monte Foods Company Lead Director and Chairman Nominating/Corporate Governance (sold to KKR); Pactiv Corporation, Audit (sold to Reynolds Holdings); Royal Dutch Shell, plc Audit, Remuneration, Corporate Social Responsibility committees; Hunt Manufacturing Company Audit, Compensation (sold to Berwind).

She was a Bestfoods Corporate Vice President and also President, Bestfoods Grocery’s $1.3 billion U. S. consumer  business (Hellmann’s, Skippy, Mazola, Mueller's); Vice President Bestfoods Food Service Global Development $1.7 billion (Europe, Asia, Latin America, North America); President, Bestfoods Specialty Markets Group (Canada, United States, Caribbean, Worldwide Exports) food/non-food brands for North American General Market, Hispanics and Asians consumers. Prior to her general management positions, she held numerous marketing positions including Vice President Marketing Bestfoods Baking (Thomas’, Sahara). Bestfoods ($9.4 billion) was sold to Unilever.

Nina is Managing Partner Henderson Advisory which provides consumer industry evaluation to investment firms.

She is a Trustee of Drexel University and  the Drexel College of Medicine, Chairman Academic Affairs and member Executive and Finance committees; a Director Visiting Nurse Service of New York, Executive and Finance; Director, Foreign Policy Association.

Peter Clark is senior counsel in the White Collar Defense and Investigation and Complex Litigation Practices, resident in the Washington D.C. office.

Prior to joining Cadwalader, Peter served as Deputy Chief of the Fraud Section of the Criminal Division of the Department of Justice, where he had previously held the position of Senior Litigation Counsel. Before his tenure at the DOJ, he was Special Counsel in the Division of Enforcement of the Securities and Exchange Commission, which he joined at the request of William Casey, then Chairman of the SEC.

Prior to his government service, Peter was with New York's Hall, Casey, Dickler & Howley, where he worked on securities, real estate, and tax litigation matters.

Among his many accomplishments, Peter has handled hundreds of voluntary disclosures of illicit corporate payments and securities enforcement matters both at the SEC and the DOJ, and successfully prosecuted the first transnational bribery cases brought by the Department. He played an important role in the enactment and subsequent amendments to the Foreign Corrupt Practices Act (FCPA), and was the Department's principal negotiator of the Organisation for Economic Co-operation and Development’s (OECD) anti-bribery convention and the Council of Europe Criminal Law Convention. He has worked closely with The World Bank and other international organizations in their implementation of anti-corruption compliance programs. Peter was a founder of the Justice Department's Securities and Commodities Fraud Working Group. As Deputy Chief of the Fraud Section, Peter was responsible for all of the Department's FCPA investigations and prosecutions, and for the FCPA Opinion Procedure. 

Peter was presented with the 1998 Award for Outstanding Government Lawyer by the American Bar Association Section of International Law and Practice for his role in enforcing the FCPA and in negotiating the OECD Convention. Most recently, he was recognized as an “FCPA Master” by Main Justice for his record of achievement in anti-corruption defense work.  Ethisphere Institute honored Peter in their 2012 Attorneys Who Matter Hall of Fame, Ethisphere's highest honor given to a practicing attorney, and named him a "Top Gun" lawyer in its 2011 Attorneys Who Matter.  Peter was also recognized by Who's Who Legal's The International Who's Who of Business Crime Defence Lawyers in 2014 and 2012, and by Benchmark Litigation.   Peter has been a member of the Advisory Committee on International Economic Policy of the U.S. Department of State. He is a member of the Board of Directors of Transparency International-USA.

Peter is a graduate of Brown University and the University of Pennsylvania Law School. He has lectured extensively before professional associations both domestically and internationally. He is admitted to practice in the District of Columbia and the State of New York.

Sarah Erickson is the Associate General Counsel - International for Ecolab Inc., responsible for Ecolab's legal matters outside the United States.  She has primary responsible for Ecolab's FCPA compliance program. In addition, Sarah has handled numerous international acquisitions and other transactions as well as serving in a variety of other roles including antitrust, dispute and litigation management, corporate governance and SEC compliance.   

With sales of $11 billion and more than 40,000 employees, Ecolab Inc. (NYSE: ECL) is the global leader in water, hygiene and energy technologies and services that provide and protect clean water, safe food, abundant energy and healthy environments. Ecolab delivers comprehensive programs and services to the food, energy, healthcare, industrial and hospitality markets in more than 160 countries.

Sarah received her B.A. from the University of Minnesota Duluth, graduating magna cum laude and received her J.D. from the University of Minnesota, graduating cum laude. 

Susan Ringler joined Alcoa in June 2013 as Vice President and Chief Ethics & Compliance Officer.  In this function, Sue leads Alcoa's global ethics and compliance programs and ensures alignment to Alcoa's Values as well as compliance with applicable regulations. She oversees Alcoa’s Anti-Corruption and Trade Compliance Programs.

Prior to joining Alcoa, she was a Deputy General Counsel at Xylem Inc., a global water technology company that was spun off from ITT Corporation in 2011. She is the former Sr. Counsel for International Compliance at ITT, where she where she created and implemented its first global anti-corruption program.

Earlier in her career, Sue served as General Counsel under Chairman Paul Volcker of the Independent Inquiry Committee investigating the United Nations Oil for Food Programme, a large international corruption investigation spanning six continents. She also investigated fraud and corruption in World Bank-financed projects, and worked on developing best practices for investigations. As part of her work with the American Bar Association's Central and East European Law Initiative, Sue developed and managed criminal justice reform assistance and training programs in Russia and the former Soviet Republics. From 1985-1998, Sue served as an Assistant U.S. Attorney with the U.S. Attorney’s Office for the District of Maryland, where she worked in the White Collar Fraud Group prosecuting complex federal fraud and corruption cases.

Sue earned a Juris Doctor Degree from Catholic University, Columbus School of Law, Washington, D.C., where she was a member of the Law Review.   She obtained her bachelor's degree in Government from Franklin and Marshall College in Lancaster, PA.

Sue is a member of the board of directors of the CEELI Institute in the Czech Republic, a global institution dedicated to enhancing the rule of law by providing legal education to lawyers, judges, prosecutors and other reformers worldwide; a member of the Sanctions Board for the African Development Bank; serves on the American Conference Institute's Global Anti-Corruption Advisory Board; and is a member of the Franklin & Marshall College Leadership Council.

Timothy L. Dickinson is a partner in the Washington D.C. office of Paul Hastings with over 30 years’ experience in the field of anti-corruption law. Mr. Dickinson’s practice encompasses a number of areas, including all aspects of the Foreign Corrupt Practices Act, U.S. export laws, economic sanctions, ITAR regulations (including enforcement actions), and political risk insurance.

Mr. Dickinson works closely with a wide range of industries on FCPA matters, including establishment of compliance programs, due diligence in acquisitions, special investigations and defense before regulators in the U.S. as well as abroad, including the U.K.'s Serious Fraud Office. In 2005, he was appointed Independent Expert by Monsanto as part of a Deferred Prosecution Agreement with the Department of Justice and he recently concluded a three-year term as Independent Monitor in conjunction with a case settled in 2010.  Mr. Dickinson was also selected by the World Bank to assist with the development of their Voluntary Disclosure Program, and participated with Bank staff in evaluating and recommending improvements to a VDP participant's compliance program.  Chambers USA 2009, 2010, 2011, 2012 and 2013 have recognized him among the very few attorneys ranked as top-tier FCPA experts; he was also named by Ethisphere at the top of their FCPA 2009 list of Attorneys Who Matter.

Mr. Dickinson also represents political risk insurance entities dealing with coverage issues, arbitration of disputes, and recovery activities.  He has worked on major infrastructure projects in the Middle East and Asia and has represented foreign governments in matters involving public international law; including treaty rights, expropriation, and sovereign immunity.

Mr. Dickinson was an adjunct professor of law at Georgetown University Law Center from 1983 to 1993.  He is currently a Professor from Practice at The University of Michigan Law School where he teaches Transnational Law and International Commercial Transactions, and is a founding faculty member of the International Transactions Clinic, which gives students practical experience in international law. He served as the chair of the ABA Section of International Law and Practice in 1997-1998, has served on the Executive Council of the American Society of International Law and serves as Director of the International Law Institute’s course on government integrity and anti-corruption initiatives.  Mr. Dickinson is chairman of the ABA's International Legal Resource Center, which provides global legal assistance in conjunction with the United Nations Development Programme.  He served as Co-Chair of the International Bar Association's Anti-Corruption Committee for 2012-2013.

Mr. Dickinson graduated from The University of Michigan law school in 1979 after completing his B.A. in 1975.  He also studied at The Hague Academy of International Law in the Netherlands and L'Université d'Aix-Marseille in France and spent a brief period as an extern in the Office of the Legal Adviser of the Department of State.  Following law school, he earned his LL.M. as a Jervey Fellow at Columbia University.  After finishing his LL.M. degree, Mr. Dickinson worked in the Legal Service of the Commission of the European Communities in Brussels, Belgium.  Mr. Dickinson then returned to Washington, D.C., where he entered private practice.

A partner in the Litigation Department of Paul, Weiss, Rifkind, Wharton & Garrison LLP, Mark F. Mendelsohn is co-chair of the Anti-Corruption & FCPA Group, a member of the firm’s White Collar and Regulatory Defense, and Securities Litigation Practice Groups. Prior to joining Paul, Weiss, Mr. Mendelsohn served as the deputy chief of the Fraud Section of the Criminal Division of the United States Department of Justice (DOJ), and is internationally acknowledged and respected as the architect and key enforcement official of DOJ’s modern Foreign Corrupt Practices Act (FCPA) enforcement program. He is widely known for dramatically increasing the level of sophistication of FCPA enforcement globally and for underscoring the importance of anti-corruption compliance. Prior to joining the Fraud Section, Mr. Mendelsohn was senior counsel in the DOJ’s Computer Crime and Intellectual Property Section in Washington, D.C., and prior to that served for nearly six years as an assistant U.S. attorney in the Southern District of New York.


J.D., University of Virginia School of Law, 1993

B.A., Yale University, 1989


Hon. Denny Chin, U.S. District Court, Southern District of New York



Lawdragon “500 Leading Lawyers in America”

The Best Lawyers in America

Who’s Who Legal

Raja is responsible for oversight of the company’s Compliance program, including Financial Crimes Compliance, as well as other global risk responsibilities.  He also participates in Tishman Speyer’s Investment and Management Committees.

Raja previously worked at Morgan Stanley for ten years as the Global Head of the Anti-Corruption Group, the Global Head of Special Investigations, and the Firm’s Global Franchise Committee Officer.

Prior to joining Morgan Stanley, Raja was a prosecutor for ten years, most recently at the Department of Justice, Criminal Division, Fraud Section, in Washington, DC.  Raja also served as an Assistant District Attorney at the New York County District Attorney's Office.

Richard W. Grime is a litigation partner in the Washington office of Gibson, Dunn & Crutcher’s Washington, DC office and a member of the White Collar Defense and Investigations Practice Group and the Securities Enforcement Practice Group. 

Mr. Grime’s practice focuses on representing companies and individuals in corruption, accounting fraud, and securities enforcement matters before the Securities and Exchange Commission and the Department of Justice.  Mr. Grime also conducts internal investigations and counsels clients on compliance and corporate governance matters with a particular focus on corruption investigations.

Richard spent over nine years in the Division of Enforcement at the Securities and Exchange Commission in Washington, DC.  In his last four years at the Commission he was an Assistant Director.  While at the SEC, Mr. Grime supervised the filing of over 70 enforcement actions covering a wide range of the Commission’s activities including a series of FCPA cases including the first FCPA case involving SEC penalties for violations of a prior Commission order.

Richard is ranked as a nationwide "FCPA Expert" by Chambers USA 2011-2014 and Chambers Global 2012-2014.

Alexandra Wrage is the president of TRACE. She is also the editor of How to Pay a Bribe: Thinking Like a Criminal to Thwart Bribery Schemes, the author of Bribery and Extortion: Undermining Business, Governments and Security and the host of the training DVD Toxic Transactions: Bribery, Extortion and the High Price of Bad Business produced by NBC. Ms. Wrage has written three compliance guidebooks and is a guest blogger on the Huffington Post. She speaks frequently on topics of international law, innovative compliance initiatives and the hidden costs of corruption, and regularly authors articles appearing in the business and legal media, including a bi-weekly column for Corporate Counsel.
Ms. Wrage currently serves on the Independent Governance Committee (IGC) of the Fédération Internationale de Football Association (FIFA), football's governing body.  She has previously served as Chair of the Anti-Corruption Committee of the ABA's International Section and Chair of the International Legal Affairs Committee of the Association of Corporate Counsel.  She has participated in anti-bribery working groups with the OECD and the UN Global Compact. Ms. Wrage was named one of the "Canadians Changing the World" by the Toronto Globe and Mail in 2011 and one of Maryland's Top 100 Women and Most Admired CEOs for 2012 by the Daily Record.
Prior to founding TRACE, Ms. Wrage was international counsel at Northrop Grumman where she was responsible for managing and improving the company's compliance program, including policy revisions, training, monitoring and board briefings.  
Ms. Wrage, a Canadian, studied law at Kings College, Cambridge University. She lives now in Annapolis, Maryland, with her husband and two sons.

Alistaire Bambach has been an Assistant Regional Director and Chief Bankruptcy Counsel to the Division of Enforcement since 2001. She was previously a Senior Trial Counsel in the Division of Enforcement. Ms. Bambach obtained a B.S. in Industrial and Labor Relations from Cornell University in 1983 and a J.D. in 1986 from the University of Houston Law Center. From 1986-1987, she was a law clerk for the Hon. Carl O. Bue, Jr., United States District Judge, Southern District of Texas. From 1988-1994, Ms. Bambach was associated with the firm of Weil, Gotshal & Manges in New York.  Since 1995, Ms. Bambach has worked at the United States Securities and Exchange Commission. In her current position Ms. Bambach is counsel to the SEC's Enforcement Division on all bankruptcy and insolvency matters, and has oversight over the SEC's receivership program. Ms. Bambach is also responsible for investigating and litigating complex financial fraud cases which result in corporate insolvencies. These cases include Enron, WorldCom, Adelphia, Lehman, Madoff and MF Global. Ms. Bambach is a frequent lecturer on the SEC's practices and procedures and on the intersection of the federal securities laws and bankruptcy and insolvency law. In 2006, Ms. Bambach received the Stanley Sporkin Award.

Brian Whisler is a member of Baker & McKenzie's Investigations and Business Crimes Group, and Global Compliance Group. He is a regional leader in the areas of business crimes, investigations, corporate compliance and governance. Mr. Whisler focuses his practice on internal investigations, regulatory advice, white collar criminal defense and civil litigation. Prior to joining Baker & McKenzie, Mr. Whisler served as the Criminal Chief Assistant United States Attorney in Richmond, Virginia, Eastern District of Virginia, where he managed the criminal trial practice of over 25 prosecutors handling cases ranging from white collar crime, violent crime, public corruption and terrorism, and focused his own trial practice on white collar prosecutions of health care fraud, securities fraud, money laundering, and tax fraud. He also served for ten years as an Assistant United States Attorney for the Western District of North Carolina where he focused on white collar prosecutions and served as Chief of Appeals and Health Care Fraud Coordinator.

Practice Focus

Criminal and Civil Litigation; Anti-Corruption; Anti-Money Laundering Compliance; Securities Enforcement/Litigation

Mr. Whisler is experienced in handling a broad range of civil and criminal matters, including Foreign Corrupt Practices Act, Bank Secrecy Act, money laundering, health care, securities, and procurement fraud, and export controls issues. He has provided guidance in investigations as well as regulatory advice to multinational and domestic clients in oil and gas services, pharmaceuticals, financial services, manufacturing, and telecommunications. Additionally, Mr. Whisler has developed compliance programs for Fortune 50 corporate clients, guided companies and individuals in government investigations in multiple global jurisdictions and defended clients in criminal and civil litigation.

Professional Affiliations

Adjunct Professor, University of Richmond, T.C. Williams School of Law (2004-2008)
Member, Association of Certified Anti-Money Laundering Specialists


  J.D., George Mason University School of Law (1989)
  B.A., Grove City College (1985)

Bar Admissions:

 Virginia (1989)
  North Carolina (1994)

Charles Cain is the Deputy Chief of the Foreign Corrupt Practices Act Unit within the Securities and Exchange Commission’s Division of Enforcement.  He has been in the SEC’s FCPA Unit since its formation and with the Division of Enforcement for seventeen years.  As the Deputy Chief, his roles include oversight of the National FPCA program, coordination with the DOJ and FBI, and supervision of individual investigations.  During his tenure with the SEC, he has been responsible for numerous significant FCPA matters, as well as cases across a broad range of other areas including financial fraud, insider trading, offering fraud, market manipulation, disclosure fraud, and broker dealer practices.

Cheryl Scarboro, Partner at Simpson Thacher & Bartlett LLP, was formerly the first Chief of the SEC’s FCPA Unit, represents corporations, financial institutions and individuals in SEC and other regulatory enforcement proceedings. Cheryl conducts internal investigations and counsels clients on FCPA compliance programs, SEC reporting, disclosure and corporate governance requirements. She was recognized as one the “25 Most Influential Women in Securities Law” by Law360,  is consistently listed in the “Top 250 Women in Litigation” by Benchmark Litigation, and was named to the “Enforcement 40” by the Securities Enforcement Forum. Cheryl is consistently recommended by The Legal 500 in white collar and was named a National “Litigation Star” by Benchmark Litigation. In addition, she is a member of the Board of Visitors of Duke University School of Law.

Chris Cummings is a partner in the Corporate Department and a member of the firm's Capital Markets and Securities and Canadian Practice Groups. Based in Toronto, he practices U.S. securities law with a particular emphasis on cross-border capital markets and mergers and acquisitions. He has worked on a broad range of public and private transactions for investment banks and companies in a number of industries, including oil and gas, mining, insurance, transportation, computer hardware and software development and telecommunications. Chris is a graduate of Vanderbilt University Law School and Duke University.

Claudius Sokenu, a former federal regulator with the Securities and Exchange Commission, is a partner in the firm’s Litigation Group where his practice focuses on representing financial institutions, public and private companies, accounting firms, and their Boards of Directors, Audit Committees, directors, officers, and employees in securities  enforcement actions and litigations, white collar criminal defense, derivative actions, internal investigations and crisis management, congressional investigations, and complex commercial litigations in state and federal courts. Claudius has extensive experience in handling delicate high-profile matters that require concurrent representation in the civil,  criminal,  and political spheres.

Earlier in his career, Claudius served in the Washington, DC office of the SEC’s Enforcement Division, on the Honors Program, first as a Staff Attorney and later as Senior Counsel, where he was responsible for handling a  broad range of domestic and international enforcement matters, including investigations involving accounting fraud, insider trading, initial public offerings, illicit payments under the FCPA, investment companies and investment advisers, market manipulation, and broker-dealer misconduct. He was also a member of the Enforcement Division’s  FCPA Working Group, which is now known as the FCPA Unit.

Consistently ranked by Chambers USA and Chambers Global for his investigative, regulatory, and securities enforcement practice, named a Litigation Star by Benchmark Litigation (2015), named a rising star by Ethisphere in its national annual rankings of “Attorneys Who Matter” (2012), named a “Top Lawyer” by The Network Journal (2011), recognized by Securities Law 360 as one of its 10 under 40 (2007), and named by Main Justice as one of the Best FCPA Lawyers Outside the Beltway (2011), Claudius has represented major companies and/or their officers and directors, including Allianz SE, Bank of New York, CIBC World Markets, GlaxoSmithKline, Bank of America, Ernst & Young Global, Avon Products, CVS Caremark, Arthur Andersen LLP, Amgen, Walmart, Bristol-Myers Squibb, Kraft Foods, Embraer, Cardinal Health, and TV Azteca before prosecutors and regulators in the United States and abroad and in federal and state courts on bet- the-farm matters.

Claudius Sokenu, a former federal regulator with the Securities and Exchange Commission, is a partner in the firm’s Litigation Group where his practice focuses on representing financial institutions, public and private companies, accounting firms, and their Boards of Directors, Audit Committees, directors, officers, and employees in securities  enforcement actions and litigations, white collar criminal defense, derivative actions, internal investigations and crisis management, congressional investigations, and complex commercial litigations in state and federal courts. Claudius has extensive experience in handling delicate high-profile matters that require concurrent representation in the civil,  criminal,  and political spheres.

Earlier in his career, Claudius served in the Washington, DC office of the SEC’s Enforcement Division, on the Honors Program, first as a Staff Attorney and later as Senior Counsel, where he was responsible for handling a  broad range of domestic and international enforcement matters, including investigations involving accounting fraud, insider trading, initial public offerings, illicit payments under the FCPA, investment companies and investment advisers, market manipulation, and broker-dealer misconduct. He was also a member of the Enforcement Division’s  FCPA Working Group, which is now known as the FCPA Unit.

Consistently ranked by Chambers USA and Chambers Global for his investigative, regulatory, and securities enforcement practice, named a Litigation Star by Benchmark Litigation (2015), named a rising star by Ethisphere in its national annual rankings of “Attorneys Who Matter” (2012), named a “Top Lawyer” by The Network Journal (2011), recognized by Securities Law 360 as one of its 10 under 40 (2007), and named by Main Justice as one of the Best FCPA Lawyers Outside the Beltway (2011), Claudius has represented major companies and/or their officers and directors, including Allianz SE, Bank of New York, CIBC World Markets, GlaxoSmithKline, Bank of America, Ernst & Young Global, Avon Products, CVS Caremark, Arthur Andersen LLP, Amgen, Walmart, Bristol-Myers Squibb, Kraft Foods, Embraer, Cardinal Health, and TV Azteca before prosecutors and regulators in the United States and abroad and in federal and state courts on bet- the-farm matters.

Bar Admissions

New York

District  of Columbia


Georgetown University Law Center, LLM in Securities  and Financial Regulation

London School of Economics  and King’s College London, University of London, LLM in Commercial  and Corporate Law

South Bank University, London, LLB, Upper Class  Honors

Greta Lichtenbaum, a partner in O’Melveny and Myers’ Washington, D.C. office, has been advising clients on anti-corruption compliance for over two decades, and has worked with clients in a range of business sectors, including defense, energy, finance, high-tech, and pharmaceuticals.  As the U.S. Government’s expectations concerning FCPA compliance programs have increased, Greta has worked closely with clients as they enhance and refine their compliance mechanisms to mitigate corruption risk. In addition to the FCPA, she has deep experience in the area of economic sanctions and export control laws. She has often been asked to develop parallel compliance mechanisms to mitigate both anti-corruption and trade controls risks, and understands how these areas of risk inter-relate.  Greta is ranked in both Chambers USA and Chambers Global.   She is a frequent speaker on legal issues at business groups and bar associations.  Greta received her law degree from Harvard University in 1990.

LUCINDA A. LOW is a partner in the Washington, DC office of Steptoe & Johnson LLP, where she heads the firm's Chambers-ranked FCPA and anti-corruption practice and its Compliance, Investigations, Trade and Enforcement Department. Her white collar practice focuses on the U.S. Foreign Corrupt Practices Act and other anti-corruption laws, as well as other laws and regulations, including economic sanctions and AML laws, that have an extraterritorial impact on multinational businesses, as well as multijurisdictional regulatory and enforcement matters. Ms. Low has extensive experience in internal and government investigations involving their overseas businesses, representing companies, Audit Committees and Board of Directors, and individuals.  She represents clients in enforcement matters before the U.S. Department of Justice, Securities and Exchange Commission, and the World Bank and other international financial institutions. Ms. Low's practice also includes compliance counselling and representation in investment disputes between commercial parties and host governments, including disputes involving issues of fraud and corruption.  She received a #1 Ranking, Chambers Global 2010-2015, International Trade: FCPA Experts.  Ms. Low is listed in Best Lawyers in America 2012-2015, International Arbitration: Government and International Trade and Finance Law. Ms. Low is in Washington, DC Super Lawyers, International, 2014-2015.

Ms. Low is a member of the Board of Directors of Transparency International-USA and serves on its Executive Committee, and has received numerous awards for her work in this area.  In fact, the Global Investigations Review has named her recently to its 2015 “Women in Investigations:  One Hundred Investigation Specialists from Around the World.”  Ms. Low is a Presidential appointee to the Panel of Conciliators of the International Centre for the Settlement of Investment Disputes.  She also currently serves on the secretary of state’s advisory committee on international law and is president-elect of the American Society of International Law.  Ms. Low speaks Portuguese, Spanish and French, and has some knowledge of Russian, Italian and Japanese.

Lynn Neils is a partner in the firm’s New York office and a member of the White Collar Defense & Investigations Practice Group. Her practice focuses on white collar criminal defense, corporate compliance and internal investigations, regulatory enforcement matters and complex commercial litigation.

Ms. Neils served as an Assistant United States Attorney in both the Southern District of New York (SDNY) and the District of New Jersey. During her more than 11 years as an Assistant United States Attorney, Ms. Neils worked on a wide variety of cases, including securities fraud, accounting fraud, bank fraud, tax fraud, wire fraud, money laundering, health care fraud, art fraud, insurance fraud, Foreign Corrupt Practices Act, US sanctions and obstruction of justice matters. In 2004, she was promoted to Chief of the Major Crimes Unit in the SDNY where she supervised approximately 20 senior Assistant United States Attorneys in handling the investigation and prosecution of a wide variety of complex white collar cases.

For several years, Ms. Neils also served a Senior Counsel at Johnson & Johnson and was responsible for handling a large caseload of criminal and civil matters; conducting internal investigations; advising on compliance and regulatory matters, including those related to the FCPA; and conducting training of employees on regulatory and legal matters, including those related to the FCPA and other anti-corruption laws and regulations.


  • Engaged by a Fortune 500 Life Sciences company to coordinate the investigation of suspected FCPA violations in India, Ukraine, China and Brazil, and to advise the company’s Internal Audit Department on conducting FCPA audits to ensure compliance.
  • Engaged to represent several current and former employees of a Life Sciences company under investigation for alleged violations of the Food, Drug and Cosmetic Act.
  • Engaged by a large Hong Kong trading company to give advice related to the FCPA in connection with the negotiation of an agency agreement.
  • Engaged by a former analyst for a Hedge Fund in connection with New York an SEC investigation into alleged market manipulation and insider trading.
  • Engaged by a large public Financial Services company to conduct an internal investigation into alleged accounting irregularities.
  • Represented a large electronics company in an internal investigation into allegations it assisted a public company in falsely inflating its sales numbers.
  • Engaged by a large Oil and Gas company to conduct FCPA due diligence in connection with a proposed acquisition.
  • Represented a Director of a Broker/Dealer that was under investigation by the U.S. Attorney’s Office for the Southern District of New York and the Securities Exchange Commission for securities fraud.
  • Represented the Chief Compliance Officer of a Broker/Dealer in an SEC Enforcement action involving allegations of churning in customer accounts.


U.S. Attorney's Office, Southern District of New York (SDNY) and The District of New Jersey, Assistant United States Attorney; Southern District of New York (SDNY), Chief of the Major Crimes Unit Johnson & Johnson, Senior Counsel


American Bar Association - Member of the White Collar Crime Committee of the Business Law Section; Co-Chief, Securities Fraud Subcommittee

Association of the Bar of the City of New York - Member of the Committee on the Judiciary (2002-2005); Federal Bar Council; Lecturer at Rutgers Business School on Criminal Law and the FCPA (2007-2009)

MARK MORRISON is a partner in Blakes Litigation Group with a focus on anti-corruption compliance, white-collar crime defence, competition and commercial litigation. Mark regularly advises Canadian and multinational corporate clients on compliance with domestic and international anti-corruption legislation, undertakes internal anti-corruption audits and investigations, assists clients with anti-corruption due diligence during mergers and acquisitions and has successfully defended complex Criminal Code anti-corruption cases.  Mark has undertaken internal anti-corruption investigations and assisted companies in resolving anti-corruption issues arising from conduct in Africa, Central America, South America and Asia. Examples of Mark's experience defending corporate clients and individuals in white-collar crime cases include defences such as: numerous Criminal Code matters including charges alleging bribery of public officials and cross-border conspiracy charges; Competition Act charges of bid rigging and allegations of price fixing; Occupational Health & Safety charges; environmental charges; and matters before the Securities Commission. Mark has been recognized as one of Canada's leading Business Crime Defence lawyers in the International Who's Who of Business Crime Defence Lawyers.

Martin J. Weinstein is a partner in the Litigation Department of Willkie Farr & Gallagher LLP and leads the Compliance & Enforcement Practice Group. Mr. Weinstein represents Fortune 500 companies and their Audit Committees or Boards of Directors in a wide variety of foreign business practices, compliance, and white-collar matters, including the FCPA and financial fraud. He regularly designs and benchmarks corporate compliance programs, conducts internal investigations worldwide, and counsels on a variety of foreign business practice areas involving export controls, trade sanctions, and related matters. He also negotiates business transactions and represents clients before federal and state authorities, as well as before Congress.

Chambers USA and Chambers Global have given Mr. Weinstein tier 1 rankings since 2007. Mr. Weinstein was also named one of the "100 Most Influential People in Business Ethics" in 2007, and as one of the "Attorneys Who Matter" by Ethisphere Magazine in 2009, 2010, 2011, and 2012.
In 25 years of practice, Mr. Weinstein has handled numerous sensitive complex investigations and litigation matters involving international, financial, and political issues. For example, Mr. Weinstein:

  • Defended or prosecuted many of the biggest FCPA cases in history
  • Tried nearly 40 federal jury trials across the country
  • Represented Boards of Directors and Audit Committees of major multinationals in sensitive investigations or government enforcement actions
  • Represents a major multinational oil company in defending charges of human rights abuses
  • Developed compliance programs for many of the Fortune 500
  • Represented the Director of Export Compliance for a major defense contractor
  • Represented one of the two major political parties in the 1996 Campaign Finance investigation carried out by various Congressional Committees and Justice Department prosecutors
  • Represented the Commissioner of Major League Baseball in the Pete Rose matter


University of Virginia JD, 1984
Dartmouth College BA, 1981

Steven Tyrrell serves as co-chair of the firm's White Collar Defense & Investigations Group. His practice focuses on white collar criminal defense, regulatory enforcement matters, and internal investigations.

Mr. Tyrrell previously served as Chief of the U.S. Department of Justice's Fraud Section from 2006 through 2009. In that capacity, he led the investigation, prosecution, and coordination of a broad range of sophisticated economic crime matters and enforcement initiatives, including matters involving the Foreign Corrupt Practices Act, corporate, securities, commodities and investment fraud, health care fraud, procurement fraud, stimulus and rescue fraud, mortgage fraud, consumer fraud, and identity theft. He also played a key role advising Department leadership on white collar crime-related legislation, crime prevention, public education and the Department's Financial Fraud Enforcement Task Force.

Prior to Mr. Tyrrell's appointment as Chief of the Fraud Section in 2006, he served as Deputy Chief of the Counterterrorism Section of the Criminal Division, where he supervised a team of attorneys in connection with the investigation, prosecution, and coordination of a variety of international terrorism and terrorist financing matters. Mr. Tyrrell also led a number of high-profile national security investigations and trained federal prosecutors and agents on relevant national security statutes, policies and practices.

Mr. Tyrrell also served as an Assistant US Attorney in the US Attorney's Offices in the Southern District of Florida and the Northern District of New York. During his more than fifteen years as an Assistant US Attorney, Mr. Tyrrell investigated and prosecuted a variety of criminal cases, with an emphasis on white collar matters, including but not limited to securities fraud, health care fraud, government contract fraud, bank fraud, tax fraud, FDA fraud, and public corruption, as well as related money laundering and asset forfeiture work. He also was lead counsel for the United States in nearly forty criminal jury trials.

Early in his career, Mr. Tyrrell served as Law Clerk to the Honorable Thomas J. McAvoy, United States District Court Judge for the Northern District of New York.

Mr. Tyrrell is the recipient of the Attorney General's Award for Distinguished Service (2005), the Inspector General's Integrity Award, Department of Health and Human Services (1999), the Timothy J. Evans Memorial Award, U.S. Attorney's Office (S.D. Fla., 1998), and numerous citations and letters of commendation

Mr. Tyrrell is a recognized expert and frequent speaker on a host of white collar topics, including FCPA enforcement, securities fraud, corporate charging decisions, use of deferred and non-prosecution agreements, and monitors.

Thomas McCarthy, Jr. is a trusted advisor to clients engaged in global trade and operations in the areas of compliance, integrity and governance, including corporate governance, international internal investigations, and anti-bribery and World Bank integrity compliance, monitoring and antifraud mechanisms.

Practice & Background

Mr. McCarthy has extensive experience in national and international anti-bribery and anti-corruption compliance laws and standards, as well as World Bank integrity and sanctions regimes, and in conducting international internal investigations, and developing compliance programs to combat internal and external fraud for companies operating in the global marketplace, as well as in developing effective risk mitigation measures and voluntary disclosure programs. Prior to joining Akin Gump, he was a senior institutional integrity officer for the World Bank Group. In that role, he directed and conducted numerous international investigations and served as a member of the Special Litigation Unit, overseeing the planning, processing and prosecution of debarment proceedings before the World Bank Sanctions Board, as well as criminal referrals to national governments deriving from investigations.

Mr. McCarthy's experience includes internal investigations relating to procurement processes and allegations of fraud and corruption involving multimillion-dollar government contracts. In the course of his investigations, he has worked in close coordination with U.K., German and other European law enforcement authorities, as well as U.S. law enforcement authorities, including the Federal Bureau of Investigation (FBI), the Internal Revenue Service (IRS), the Securities and Exchange Commission (SEC), U.S. Attorneys' offices and the Department of Justice (DOJ). Internationally, he has worked on investigations arising in the United Kingdom, Germany, India, China, Indonesia, Cambodia, Thailand and Laos.

In addition, Mr. McCarthy has served as general counsel to health care companies, where he was responsible for ensuring full compliance with complex federal and state regulations, including False Claims Act, Stark I and II, antikickback and RICO, as well as compliance with Department of Health and Human Services Office of the Inspector General (OIG) preliminary and final voluntary disclosure programs and protocols.

Mr. McCarthy is a member of the International Bar Association.