Anti-Corruption & Foreign Corrupt Practices Act
Anti-Corruption & Foreign Corrupt Practices Act
Our team has unsurpassed experience in counseling and defending U.S. and foreign companies and individuals in matters relating to the U.S. Foreign Corrupt Practices Act and similar anti-corruption laws. We are frequently contacted when a potential corruption issue arises, and are go-to counsel for investigations and enforcement proceedings before the U.S. Department of Justice (DOJ), the Securities & Exchange Commission (SEC) and the Multilateral Development Banks, including the World Bank. In addition, we advise clients considering transactions in high-risk markets or with business partners with high anti-corruption risks. We also counsel clients who are designing compliance programs and in conducting risk assessments.
Paul, Weiss Client Achieves Successful Result in World Bank Sanctions Hearing
- Client News
- July 7, 2015
Practices
The World Bank Sanctions Board has determined that a Paul, Weiss public sector software company client is not subject to a period of debarment in connection with proceedings brought by the World Bank Vice Presidency for Integrity (INT), which had sought a three-year debarment. INT had alleged that the client committed the sanctionable act of corrupt practices by giving a paid internship, and subsequently an employment contract, to the daughter of a Mongolian government official to influence the procurement processes in connection with a pair of World Bank-financed Mongolian government information technology contracts. After a hearing on the merits, the sanctions board found that while the client company had engaged in corrupt practices, the appropriate sanction was a private letter of reprimand without debarment or any prejudice to the client's eligibility to participate in World Bank-financed projects. The decision took into account several mitigating factors, including the client's establishment of an effective compliance program, the client's "extensive cooperation" with INT during the investigation, and the client's agreement to complete the contract at issue gratis. The sanctions board decision is the first published decision to impose a private letter of reprimand after concluding that a respondent had engaged in a sanctionable act.
The Paul, Weiss team included litigation partner Mark Mendelsohn.