FCPA and Anti-Corruption

Hecker Fink lawyers have a deep understanding of the intricacies of the U.S. government, foreign authorities, and the complex challenges of operating a global business. Our team, which includes eleven former federal prosecutors, counsels companies and individuals in connection with Foreign Corrupt Practices Act (FCPA) investigations and related government enforcement matters, alleged violations, internal investigations, and anti-corruption compliance.

The firm’s FCPA practice is ranked among the leading practices in the United States and globally by Chambers, which notes that the team has “strong capabilities across the board and command[s] instant credibility and respect with a sterling reputation.” Chambers Global also recognizes Sean Hecker, Mike Ferrara, and Jenna Dabbs as leading FCPA attorneys. One source remarks that “Sean is a phenomenal lawyer as well as being a very compelling and fierce advocate. He knows how to handle a case with amazing judgement. He is a great writer, orator and tactician.” Another notes that Mike “is very sharp and articulate.” Jenna is “in the spotlight for her expertise in handling government and internal investigations, as well as enforcement proceedings,” and “routinely handles high-stakes FCPA cases.”

Partner Marshall Miller brings more than a decade of experience handling FCPA and anti-corruption matters in both government and private and public sectors. At Hecker Fink and a leading international law firm, Marshall has represented companies and individuals in investigations by the U.S. Department of Justice (DOJ), U.S. Securities and Exchange Commission (SEC), and foreign government enforcement investigations, including securing declinations of prosecutions. From 2022 through 2024, Marshall served as Principal Associate Deputy Attorney General, overseeing all DOJ white-collar matters, including FCPA and kleptocracy cases. In that role, he helped develop and implement DOJ corporate enforcement policies, including the Department’s whistleblower program for white collar offenses, cross-DOJ voluntary self-disclosure policies, and compensation incentives and clawbacks program. Previously, as the Principal Deputy Assistant Attorney General for the DOJ Criminal Division and Chief of the Criminal Division for the Eastern District of New York, Marshall oversaw the Fraud Section’s FCPA Unit and the Money Laundering and Asset Recovery Section and supervised the landmark Fédération Internationale de Football Association (FIFA) corruption investigation.

Partner Amy Jeffress also conducts internal investigations and advises companies and individuals on FCPA issues. Her experience as a former federal prosecutor, DOJ Attaché, and Counselor to the Attorney General informs her strategic approach to complex cross-border investigations. She has received widespread recognition for her work, including being named by Chambers as one of Washington D.C.’s leading litigators in white collar crime and government investigations.

Select Representative FCPA and Anti-Corruption Matters

• Representation of an Asia-based energy company in connection with an FCPA investigation.
• Representation of an energy trader in connection with an appeal of a conviction for alleged FCPA violations.
• Representation of the executive director of an energy company in a DOJ FCPA investigation.
• Representation of a former employee of a non-governmental organization (NGO) in a prosecution by the U.S. Attorney’s Office for the Southern District of New York (SDNY). The client was extradited from Thailand to face charges, which included alleged conspiracy to violate the FCPA, substantive FCPA violations, and money laundering. The firm secured a plea to a single count, resulting in a sentence of time served. The judge noted that the sentence would have been reduced if possible.
• Persuaded the DOJ not to charge a former managing director of a U.S. liquified natural gas company in connection with a DOJ FCPA investigation involving the alleged payment of bribes in Jamaica, Honduras, Ecuador, and elsewhere.
• Representation of a multinational healthcare company and related entities in DOJ and SEC investigations concerning potential anti-trust and corruption issues in Brazil and China.
• Representation of a private equity firm in an ongoing FCPA and sanctions compliance review, including annual FCPA and Bank Secrecy Act/Anti-Money Laundering (BSA/AML) reviews of portfolio companies, and risk-tailored compliance advice.
• Representation of an executive at a Swiss security company in a multinational anti-corruption investigation involving the alleged bribery payments worldwide.
• Persuaded the DOJ not to charge an employee of a multinational energy and commodity trading company in connection with a DOJ FCPA investigation involving the alleged payment of bribes in Mexico, Brazil and Ecuador.
• Representation of the former foreign minister of Senegal in an FCPA complaint filed by the DOJ Fraud Section alleging conspiracy with a representative of a Chinese energy company. The firm succeeded in securing dismissal of the complaint and a non-prosecution agreement.
• Representation of an individual in the energy trading industry in a DOJ FCPA investigation involving Latin America.
• Representation of a major global insurance corporation on FCPA compliance matters.