Compliance, white-collar crime and investigations continues to be a major source of business for international law firms that have a focus on Latin America. Since the Lavo Jato scandal in Brazil, there has been an ever-increasing focus on the region amongst enforcement agencies, including the Department of Justice (DOJ) and the US Securities and Exchange Commission (SEC). The Federal Bureau of Investigations (FBI) has a Miami-based corruption squad targeting Latin America. Investigations under the US Foreign Corrupt Practices Act (FCPA) continue to be a feature of the market. White collar crime and investigations specialists are also frequently brought in as part of M&A due diligence processes.
Compliance and investigations in Latin America: International firms
Debevoise & Plimpton LLP is a global leader in international investigations and this standing is illustrated by its acclaimed track record and reputation in Latin America. It frequently advises clients on internal investigations and public investigations by civil regulators and criminal prosecutors, often involving parallel investigations in multiple jurisdictions. The firm is steeped in FCPA compliance expertise and has extensive experience in Brazil, Mexico, Colombia, Chile and other key markets. It has landed key roles in connection with Operation Lava Jato and the FIFA corruption scandal. The firm frequently represents major multinationals in cross-border investigations and regulatory defence matters, including matters involving Latin American subsidiaries, and also acts for large Latin American corporates, senior executives and individuals. Along with regular big-ticket investigations, the white collar and regulatory defence team is often involved in risk-based compliance due diligence relating to proposed M&A transactions. Andrew Levine is co-head of the Latin America group and is a ‘rock star’ in anti-corruption and investigations in the region. Washington DC partner Kara Brockmeyer previously had over 15 years working at the US Securities and Exchange Commission (SEC), including five and a half years as chief of the enforcement division’s FCPA unit. Also in Washington DC, David O’Neil has an extensive record in FCPA investigations around the world, including Latin America. Bruce Yannett is chair of the white collar and regulatory defence group. Named partners are based in New York unless stated otherwise.
Andrew Levine; Bruce Yannett
‘Debevoise & Plimpton is a firm that ensures the highest quality in its services through the organisation within the firm, the agility of response and the analytical skills of its lawyers.’
‘A highly notable characteristic of D&P attorneys is that they are thought leaders in the areas of compliance, internal investigations, and arbitration.’
‘The Debevoise office is excellent. It is an office that is not characterised by being so big, but by the quality of its professionals. Andrew Levine is a rock star at Investigations & White Collar in the Latam region. There is no expert in the region who does not know him or have interacted or worked with Andrew.’
‘Andrew Levine is an excellent lawyer, with a deep knowledge of the situation in the Latin American region in terms of anti-corruption and compliance, in which he specialises. Kara Brockmeyer is also an excellent professional, with a lot of experience re the SEC regulations.’
Marcelo Odebrecht and Emilio Odebrecht
Ontario Teachers’ Pension Plan
- Represented Ontario Teachers’ Pension Plan and Alberta Investment Management Corporation, through their controlled subsidiary Grupo Saesa in acquiring Enel Transmisión Chile, involving risk-based compliance due diligence.
Gibson, Dunn & Crutcher LLP is another global leader in FCPA and anticorruption investigations, with a number of senior practitioners that have a significant focus on Latin America. This was further augmented by the hire of Latin America specialist Bryan Parr as of counsel from Paul Hastings LLP in November 2022. The firm has an extensive record in Latin America white-collar and investigations matters, including due diligence related to M&A and other transactions. Moreover, it has an especially impressive background in FCPA monitorships pursuant to settlements with the SEC and DOJ. The practice is also noted for its prominence in investigations related to Operation Lava Jato in Brazil. Joseph Warin is chair of the litigation department and co-chair of the white-collar defence and investigations group; a leader in the field, he has a long track record in Latin America. Similarly highly rated, Los Angeles partner Michael Farhang is prominent in Latin-America-related internal investigations and M&A diligence, thanks to key roles in some of the biggest cases to have involved the region.
Stephanie Brooker; Nicola Hanna; Joseph Warin; Joel Cohen; Charles Stevens
- Engaged to represent Marsh McLennan in connection with a multi-jurisdiction investigation relating to 2014-2017 conduct at a Jardine Lloyd Thompson Group subsidiary.
- Assisted Brown-Forman in compliance-related due diligence relating to its acquisition of assets in the distillery industry.
Washington DC firm Miller & Chevalier Chartered is an established leader in corporate crime and investigations. The firm has an outstanding record in anti-corruption, anti-money laundering, sanctions, compliance and governance. It has a considerable emphasis on Latin America, with more than 20 lawyers that have a major focus on the region, many of which are Latin America natives (or have lived and worked in the region), and speak fluent Portuguese or Spanish. Brazil, Mexico, Colombia, Chile and Peru are among the firm’s primary markets. Fluent Spanish and Portuguese speaker Matteson Ellis is at the pinnacle of the market, leads the Latin America practice and is a recognised authority on FCPA cases. James Tillen is also at the forefront of investigations and compliance programmes, bringing extensive Latin America experience from the Lavo Jato scandal and many other high profile matters. Alejandra Montenegro Almonte is a pivotal member of the team and has been instrumental in building the firm’s compliance and investigations practice in Central America. Jeffrey Lehtman, William Barry and Margarita Sánchez are also key members of the Latin America-facing practice; along with fluent Spanish-and-Portuguese speaker and emerging talent, Gregory Bates. Counsel Leah Moushey is another impressive practitioner.
Matteson Ellis; James Tillen; Alejandra Montenegro Almonte
‘Miller Chevalier might be considered a “small firm” by U.S. standards, but they have, in my opinion, the most qualified and prepared team to deal with Compliance & Investigations with which I have ever work. I have already worked with plenty of U.S. law firms in FCPA related matters and Miller is, by far, the one that delivers the most. One other thing that really differentiates them from competitors is their capabilities to render services in Latin America. They have several professionals not just fluent in Portuguese and Spanish, but also used to the culture of each of the countries in which they have to work. I have worked alongside several of their professionals, including James Tillen, Matt Ellis, Kate Atkinson, Matt Reinhard, Greg Bates, Leah Moushey, Will Barry, Richard Mojica, Ann Sultan and even with their latest hire, Jeff Lehtman. I have probably forgotten a few great professionals and this is a clear evidence that they have an elite team. They are my No. 1 firm when I have to refer a U.S. law firm to any of our clients.’
‘James Tillen – he is an oracle when it comes to FCPA knowledge. In addition to that, he is extremely experienced, objective and knows where the problems are. He really knows how navigate in an internal investigation without boiling the ocean and incurring unnecessary costs. In addition to that, he has great negotiation skills that are extremely useful when a company seeks a DoJ/SEC resolution. Matt Ellis – he is a legend when it comes to Latin America FCPA related cases in Latin America. The very best a company can find if an investigation is needed in the region. Will Barry – very experienced when it comes to large problems involving Brazilian companies and their Boards; he does a fantastic job. Leah Moushey – an associate that delivers like a partner. She speaks fantastic Portuguese, is extremely responsible and the work she performs is outrageous. She is certainly a future member of the firm. Kate Atkinson – a natural born leader. She is extremely gentle in her interactions, but at the same time has the ability to technically convince the client of her point. Matt Reinhard – I have been involved with him in a Brazil related investigation and he impressed me every day with his capabilities to go straight to where the problems were.’
‘The team is readily available to help. Also, in addition to the outstanding knowledge in the field, the counsel is always to the point.’
‘Increadible knowledge; business oriented; outstanding availability.’
‘MC has the best DC-based Compliance & Anti-Corruption team for Latin American matters. Without a doubt, they are the most powerful team when it comes to FCPA, Sanctions and other investigations.’
‘It has an incredible team of partners, starting with James Tillen, Matt Ellis, Alejandra Almonde, Greg Bates, Will Barry and Jeff Lehtman.’
- Advised on the indictment of Daisy Rafoi, a Swiss National and private wealth advisor, who was arrested in Italy on an international arrest warrant issued by the US related to corruption and money laundering issues in Venezuela.
Cleary Gottlieb Steen & Hamilton
Cleary Gottlieb Steen & Hamilton has the market leading Latin America practice among international firms. This has provided the foundation for a thriving white-collar defence, investigations, anti-corruption and compliance practice in the region. It has an especially strong record in Brazil and Mexico, but nevertheless demonstrates genuine region-wide experience. The firm regularly defends clients before the Department of Justice (DOJ), the Securities and Exchange Commission (SEC) and Commodities Futures Trading Commission (CFTC), as well as representing some of the biggest corporate players in Latin America, including large state-owned businesses, major financial institutions, airlines and a number of mining giants, among others. Lisa Vicens is a Latin America specialist, having acted for big-name Latin American businesses over the years; she led the team that represented Vale in investigations of allegations that it failed to conduct appropriate diligence prior to a strategic transaction with an entity subsequently discovered to have engaged in corrupt payments. Jonathan Kolodner is another prominent practitioner with a significant focus on Latin America.
Lisa Vicens; Jonathan Kolodner
GOL Linhas Aereas Inteligentes
Copel Telecomunicacoes (COPEL)
- Represented Vale in investigations of allegations that it failed to conduct appropriate diligence prior to a strategic transaction with an entity subsequently discovered to have engaged in corrupt payments.
- Represented the Special Committee of the Board of Directors of GOL Linhas Aereas Inteligentes, in an independent investigation of alleged bribes paid to senior Brazilian officials arising out of the Lava Jato scandal, in violation of the FCPA and Brazilian law.
- Advising Brazilian telecommunications company COPEL on an investigation of allegations of bid-rigging and corruption by its mobile telecommunications subsidiary, and potential violations of the FCPA.
Covington & Burling LLP
Covington & Burling LLP is a global leader in white-collar crime and anti-corruption, and has developed a strong emphasis on the Latin America region. This growth saw Veronica Yepez, head of the Latin America anti-corruption and investigations practice, elevated to the partnership in October 2022. Many in the core Latin America group have lived and worked in the region, while the practice as a whole has an extensive record in engaging with the DOJ and SEC in anti-corruption investigations. It is also regularly engaged in anti-corruption due diligence linked to M&A and other transactions in the region. Steven Fagell is co-chair of the white-collar defence and investigations group; he too is active in Latin America matters, as is Lanny Breuer, who has an especially impressive record in white-collar crime investigations in Brazil and elsewhere in the region. Donald Ridings is global chair of the anti-corruption practice group and is an authority in FCPA investigations. Jennifer Saperstein is another key partner and Leah Saris impresses at associate level. All named individuals are based in Washington DC.
‘Covington & Burling is a law firm with a lot of involvement in the legal world. They dominate cases that involve many jurisdictions as they have a lot of experience in this regard. They are extremely agile and strict with the quality of their work.’
‘We’ve worked a lot with Leah Saris, Jennifer Saperstein, Veronica Yepez on various issues. C&B attorneys have exceptional knowledge of the law, are highly technical and practical. They always offer the customer easily applicable solutions, which is always something that is greatly appreciated.’
Special Committee of the Board of Directors of Tecnoglass
Liberty Latin America
- Advised the Special Committee of the Board of Directors of Tecnoglass, a NYSE-listed Colombian company, on the analysis of a short-seller report.
- Provided anti-corruption due diligence advice to Liberty Latin America (LLA) in connection with a number of transactions across the Latin America region.
- Represented a Brazilian company under investigation by the World Bank Group Sanctions System involving allegations that it engaged in prohibited practices in connection with World Bank-funded projects.
Davis Polk & Wardwell LLP
Davis Polk & Wardwell LLP has acted for clients in some of the biggest investigations in the Latin America market. It has worked on key matters relating to the FIFA corruption scandal, Lavo Jato and the high-profile Grupo Aval investigation; in the latter it advised Grupo Aval (Colombia’s largest financial conglomerate), on investigations by the SEC, DOJ and Colombian authorities into allegations of corruption relating to a Colombian highway construction project. Washington DC partner Daniel Kahn is the former chief of the DOJ’s FCPA unit and has worked with enforcement authorities throughout Latin America, including on a range of major FCPA resolutions. Tatiana Roesler Martins is a native Portuguese speaker and the former chief of public corruption at the US Attorney’s Office for the Southern District of New York; she is active in enforcement actions and internal investigations throughout Latin America. Native Spanish speaker Antonio Perez-Marques is also active in government and internal investigations in the region. Greg Andres and Martine Beamon are additional senior members of the practice who have a strong focus on Latin America. Named partners are based in New York unless stated otherwise.
Daniel Kahn; Tatiana Roesler Martins; Greg Andres; Martine Beamon
- Advised Grupo Aval on investigations by the SEC and DOJ, and Colombian authorities, into allegations of corruption relating to a Colombian highway construction project.
- Represented GeoPark in connection with an internal investigation related to alleged relations with illegal armed groups in the Putumayo region of Colombia.
- Represented Eletrobras in connection with an SEC investigation related to litigation reserves and related risk disclosures.
Jones Day has continued to develop its geographic coverage with additional engagements in Uruguay and Bolivia, building on its already established record in key markets such as Brazil, Mexico, Colombia and Venezuela. It has proven capability in internal investigations, enforcement and financial controls, and is a growing force in anti-money laundering and sanctions-related matters. The team is also recognised for anti-corruption due diligence relating to M&A and other transactions, and is at the forefront of anti-corruption programmes for international clients that have assets and interests in Latin America. Cristina Pérez Soto leads the Miami litigation team and is an established figure in internal investigations, anti-money laundering, sanctions and anti-corruption due diligence for transactions; she is noted for her experience in the energy and infrastructure, financial services and fintech sectors. Of counsel Guillermo Larrea is another key figure; based in Mexico City, he is frequently engaged for investigations relating to anti-corruption, anti-money laundering and fraud matters. At associate level, senior Fernando Pastore in Sao Paulo is also noted. Eric Snyder moved to McGuireWoods LLP in June 2022.
Theodore Chung; Cristina Pérez Soto
‘Great attention and professionalism, knowledge of national legislation necessary to attend an audit, ability to prepare information from a digital environment.’
‘Professionalism, adaptability to customer needs, good service.’
‘Jones Day has a relatively small office in Brazil, but whenever needed, they reach out to specialists from the other offices of Jones Day worldwide, who are exceptional on FCPA related matters.’
‘Lawyer: Artur Badra and Fernando Pastore stand out in their practice and they did a terrific work in once specific case in which we have worked jointly with them.’
‘Great presence all over the world, keeping a great level of quality in spite of its impressive size.’
‘Fernando Pastore, a senior associate able to navigate multijurisdicional white collar issues involving USA and Brazil.’
‘Great attention and professionalism, knowledge of national legislation necessary to attend an audit, ability to prepare information from a digital environment.’
‘Professionalism, adaptability to customer needs, good service.’
- Advised Daikin Industries regarding the update and revision of the compliance policies for its operations in Latin America, including with regard to exposure to corruption, and the risks associated with direct and indirect sales to governmental institutions.
- Advised Grupo Proeza on an anti-corruption programme, anti-money laundering programme, and a cybersecurity and personal data protection programme for its operations in 24 cities across North and South America and Asia.
White & Case LLP has an intense focus on Latin America, which features a well-established white-collar crime and investigations practice led by Michael Garcia and Maria Beguiristain in Miami. The department has built a strong geographic profile, based on headline engagements in Brazil and -more recently- throughout Latin America; it continues to represent some of the biggest names in Brazil, along with other Latin American businesses and an array of multinationals with interests in the region. The team is multi-lingual and has tight cultural connections to Latin America. It has achieved recognition for its expertise in FCPA investigations, internal investigations and M&A due diligence. It is also developing its name in matters related to gaming, crypto and online platforms, and has achieved further growth in US sanctions programmes. Enrique Espejel is another key figure; based in Mexico City where he co-heads the disputes practice, he is frequently engaged in internal investigations for international clients and their Mexican subsidiaries, and also has fine record in enforcement actions.
- Successfully concluded an internal investigation for Grupo CME, which was proactively launched by the company in response to an article publishing alleged improprieties in the awarding of several contracts by a state-owned company.
Diaz Reus International Law Firm & Alliance is based in Miami and has strong ties to Latin America and an established record in white-collar crime and investigations. It has a history of securing government declinations of criminal prosecutions and pre-indictment resolutions strategies in criminal investigations. The firm is widely recognised for its representation of senior executives and government officials in investigations by US law enforcement agencies; it recently acted for Alejandro Andrade, the former Treasurer of Venezuela who is serving a 10-year prison sentence, in the defence of the US government’s efforts to secure and forfeit assets and monies from third parties as part of the largest FCPA case in South Florida history. The firm also has an increasing profile in sanctions violations cases. Michael Diaz has an outstanding record in major cases involving senior executives and government officials. Robert Targ is another senior practitioner with a fine reputation in representing Latin American corporates and individuals. Marta Colomar-Garcia is a key figure in anti-money laundering cases, while Javier Coronado, Juan Vargas and Houston/Mexico-based Greg Ahlgren are also prominent practitioners in the white-collar crime area. Of counsel Jorge Schmidt, a native Spanish speaker and Latin America white-collar crime specialist, joined the firm in May 2023. All named individuals are based in Miami unless stated otherwise.
Michael Diaz; Robert Targ
Liga de Beisbol de Venezuela
Suppliex and its principal, Doenitz Walter Roman
Jesús Alebero Riera
- Acted for Alejandro Andrade, the former Treasurer of Venezuela who is serving a 10-year prison sentence, in the defence of the US government’s efforts to secure and forfeit assets and monies from third parties as part of the largest FCPA case in South Florida history.
- Acted for Liga de Béisbol de Venezuela regarding a grand jury subpoena for records and documents relating to million-dollar monies paid to it by Alex Saab, the alleged strawman for Venezuelan President Nicolás Maduro.
- Represented Felipe Alejos, a Guatemalan congressman sanctioned by OFAC under the Global Magnitsky Act, in conducting legal efforts for OFAC to reconsider the designation of Alejos on the List of Specially Designated Nationals.
Kobre & Kim
Kobre & Kim’s Latin America government enforcement and defence practice features a number of Miami-based team members. The group is frequently engaged in matters linked to investigations by the US Department of Justice (DOJ) and Securities and Exchange Commission (SEC), including multi-jurisdictional cases that have a strong Latin America element. Representing both corporates and individuals in big-ticket cases, the firm has a strong record in FCPA and money laundering violation investigations, and allegations of corruption. São Paulo partner Martin De Luca is a former DOJ prosecutor, speaks Portuguese and Spanish, and is often engaged in investigations linked to FCPA and RICO Act. Evelyn Sheehan, a former US assistant attorney in the US attorney’s office for the Southern District of Florida, is also noted for DOJ investigations, including FCPA and money laundering violations. Adriana Riviere-Badell is also recognised for regulatory and internal investigations, representing big-name US corporates and other multinationals. São Paulo lawyer Carolina Leung is another key figure. Named individuals are based in Miami unless stated otherwise. Gabriela Ruiz left the firm in May 2023.
‘Very smart capable lawyers with excellent local expertise; can provide clients with great insights based on local market, but also help bridge the gap between US expectations for compliance and investigations.’
‘Martin De Luca is a great asset on matters; very practical and has great US/LATAM experience.’
‘Kobre & Kim is a specialised boutique that has become a standard in investigations and asset recovery. Other very reputable international law firms would even refer to them as the ones to reach out to, as they have better focused capabilities. My experience with them was that I have been in touch with highly knowledgeable lawyers who are always available and very pragmatic in terms of approach.’
A global consultant in the Latin American oil and gas industry
Eight employees from a U.S. company with operations in Latin America
Former senior executive of Argentine media company
Foreign exchange trader
Atvos Agroindustrial Investimentos and Novonor
An individual who is subject to forfeiture proceedings
- Represented Atvos Agroindustrial Investimentos, the holding company of a leading ethanol producer in Brazil, which is under judicial reorganisation.
- Advised eight executives of a US company who were under investigation by US and Brazilian authorities for corrupt practices taking place in Chile, Argentina, Mexico and Brazil.
- Represented a global consultant in the Latin American oil and gas industry in connection with an investigation by the US Department of Justice into Foreign Corrupt Practices Act and money laundering violations.
Paul Hastings LLP
Paul Hastings LLP has built an enviable Latin America practice over the last decade with compliance and investigations being a core practice-segment for the group. The firm frequently represents multinationals that are facing international investigations and enforcement actions, and has also acted for major Latin American corporates regarding internal investigations and engagement with the DOJ, SEC and other agencies. The firm has a range of senior figures in the white-collar defence and investigations sphere that have extensive international experience, including matters that centre on Latin America. Robert Luskin, Nathaniel Edmonds (who chairs the litigation department in Washington DC), and John Darden, all have deep knowledge of the Latin America region. Kwame Manley, global chair of the white-collar defence and investigations group, and Corinne Lammers are also key figures in the team. Bryan Parr has left the firm to join Gibson, Dunn & Crutcher LLP.
‘The firm is sufficiently sophisticated, specialised, and large enough to deal with all matters that, although they are not strictly compliance or white collar, are essential to deal with cases comprehensively. I am referring to strong areas of data protection, labour, criminal law, taxes and litigation. This, added to the firm’s extensive experience in white collar defence issues, makes it one of the best US firms to work for.’
‘The white collar litigation practice lead by Nathaniel Edmonds is great. Also, they know the LATAM region very well which makes a difference when it comes to finding the right partner.’
‘The best investigations and anti-corruption team. They have a cohesive and multi-task practice that understands the details of each relevant market where they work.’
Petróleos del Perú (Petroperú)
SQM (Sociedad Química y Minera de Chile)
Technip Brasil Engenharia
Airbus SE and Airbus Group
CEMIG (Centrais Elétricas de Minas Gerais)
- Represented SAP before the DOJ and SEC in connection with alleged FCPA violations in Asia, Africa, and Latin America.
- Acted for Alexion Pharmaceuticals in its life sciences FCPA case before the DOJ and SEC.
- Represented Airbus Group before the DOJ in connection with investigations into an alleged worldwide scheme of unlawful payments to foreign officials to advance the sale of civilian aircraft and regarding failures to disclose relevant commissions on sales of controlled technology.
Quinn Emanuel Urquhart & Sullivan, LLP
Quinn Emanuel Urquhart & Sullivan, LLP is a global leader in litigation with a major focus on investigations, government enforcement and white-collar defence. The firm houses a number of former government officials and has an extensive record in representing corporates and individuals in major cases, including those against the DOJ, SEC, Office of Foreign Assets Control (OFAC) and the Federal Trade Commission (FTC). It has particularly notable experience in cases involving Brazilian and Mexican entities, including internal investigations and enforcement processes. The white collar and corporate investigations group features a number of Latin America-born practitioner as well as others with strong cultural links to the region. Colombian-born Juan Morillo is co-chair of the department, and Gabriel Soledad is of Mexican-American origin. Co-chair of the department, William Burck also has a strong track record in the region, including representing Latin American businesses and individuals. David Orta provides additional senior-level gravitas. All named individuals are based in Washington DC.
Juan Morillo; William Burck
‘I’ve never worked with a team of lawyers that was more talented and dedication to our case. David Orta is truly incredible to watch in action and unparalleled to any attorney I’ve worked with in litigation. Both in person and on paper, he has a way of taking complex arguments and distilling them into key persuasive components that pave the pathway for your side to win.’
‘Both David and his team are easily accessible at any time of day, any day of the week. What sets them apart from many firms is they provide clear, defensible answers to concerns about strategy, and after speaking with David or his team, you’re left feeling more confident and assured about your case and how these concerns will be addressed. They do a wonderful job of preparing for any argument the other side may have. Their witness preparation is by far harder than the questions I faced in the hearing!’
‘We had a major filing due April 2020 and the entire team, including experts, worked seamlessly from a technological perspective on the filing. In the hearing, they used technology to keep the tribunal engaged and aware of exactly where the evidence was to support our side. The team was diverse, with men and women from all over the globe working with us. The team works seamlessly to make sure everything runs smoothly.’
Roberto Jenkins de Landa, Juan Guillermo Eustace Jenkins, Alejandro González Muñoz, Carlos Román Hernández, María Elodia Jenkins de Landa, Margarita Jenkins de Landa, Juan Carlos Jenkins de Landa
J&F Investimentos, JBS, Joesley Batista, Wesley Batista
Francisco García Cabeza de Vaca
- Represented JBS, its controlling shareholder J&F Investimentos, and J&F’s ultimate shareholders Joesley and Wesley Batista, in ongoing criminal investigations and civil suits arising out of the Lava Jato and other corruption investigations around the world.
- Represented Javier Aguilar in two sets of FCPA charges and money laundering charges, alleging that he orchestrated a scheme to bribe government officals in Mexico and in Ecuador.
- Defended Francisco García Cabeza de Vaca, the former Governor of Tamaulipas, Mexico, in connection with charges by the Mexican Federal Prosecutor.
Ropes & Gray LLP represents both corporates and individuals in white-collar cases and investigations. The firm houses a large number of anti-corruption, government enforcement and white-collar crime specialists that are fluent in Spanish or Portuguese; this includes a substantial group of former federal prosecutors, including co-chairs of the firm’s global anti-corruption and international risk practice, Chicago-based partner Ryan Rohlfsen and María González Calvet, who were members of the DOJ’s FCPA unit. González Calvet also co-chairs the Latin America practice. The practice is frequently engaged by clients in relation to government investigations, internal investigations, compliance and sanctions, and its specialists in this area are also noted for due diligence relating to M&A and other transactions. The team has an exceptional record in representing life sciences, technology and healthcare businesses, along with asset managers and financial sponsors. Alexandre Rene and Ama Adams are also key members of the practice. All named individuals are based in Washington DC unless stated otherwise.
María González Calvet; Amanda Raad; Ryan Rohlfsen
‘The Ropes team is our go-to for all FCPA and internal investigation support as well as expertise in sanctions. They are user friendly, always make themselves available, are commercial and thoughtful. The team knows our firm well and it is very easy to get them read in on any matters where we need their support.’
‘Maria Calvet is like an extension of our internal team. She has helped our firm through numerous sensitive investigations as well as provided support with more routine FCPA and sanctions support at the firm level or within our portfolio. She is sharp, knowledgeable and creative!’
- Represented Avianca Holdings, Colombia’s flag carrier airline, in connection with investigations by the DOJ, the SEC, and several Colombian law enforcement and regulatory authorities.
Sidley Austin LLP has a fine reputation in Latin America, including for corporate crime investigations and engagement with US government agencies. It has a long track record in FCPA investigations and is also recognised for sanctions cases. The firm is home to a number of former federal prosecutors and former officials from the DOJ and SEC. The team frequently represents clients in headline investigations by the DOJ and SEC. The Latin America corporate crime team includes New York partners Timothy Treanor and Michael Mann, along with Dallas partners Paige Holden Montgomery and David Silva; Treanor is a former federal prosecutor and is especially active in anti-corruption and white-collar defence work in Latin America, and led the team that represented CONCACAF in the DOJ’s global investigation into corruption in world football.
Timothy Treanor; Karen Popp; James Cole; Douglas Axel; David Hoffman; Yuet Ming Tham; Daniel Rubinstein
‘It is a firm that is characterised by having professionals with outstanding experience and extensive knowledge of law.’
‘In my opinion, Sidley Austin’s Compliance and Investigations practice has a very multi-disciplinary and competent group of lawyers with large experience in different types of enforcement investigations in Latin America. They are used to dealing with different authorities in the context of negotiations.’
‘Tim Treanor and Mike Mann are very experienced lawyers with great ability to understand the client’s issues and address then in the best way possible.’
‘Great level of sophistication, experience, and market awareness.’
‘Michael Mann. A very talented and sophisticated white collar lawyer, highly experienced in dealing with complex cross-border investigations.’
CONCACAF (The Confederation of North, Central America and Caribbean Association Football)
Bodega Latina Corporation
Exxon Mobil Corporation
Vantage Deepwater Petroleum Company
PACC Offshore Services Holdings
JPMorgan Chase & Company
Franqui Francisco Flores de Freitas
Arthur J Gallagher & Co.
- Represented Stericycle in coordinated settlements resolving FCPA charges with the DOJ and SEC, and local corruption charges with Brazilian authorities.
- Represented 29 Panamanian entities that have been sanctioned by the Office of Foreign Assets Control (OFAC).
- Represented CONCACAF in the DOJ’s global investigation into corruption in world football.
Vinson & Elkins LLP frequently represents clients before the DOJ, SEC and other regulators. It has an extensive record in government and internal investigations, compliance, compliance-related advice connected to M&A and other transactions; additionally, it enjoys an especially strong reputation in the energy and technology sectors. The firm works with a range of multinationals and financial sponsors that have assets and interests in the Latin America region. It also advises Latin American businesses that are facing allegations of FCPA violation and other enforcement actions. Anti-bribery and corruption due diligence linked to transactions is another growth area for the team. New York partner Palmina Fava specialises in multi-jurisdictional investigations, often involving Latin America, and frequently advises on international compliance programmes for large global businesses. Washington DC partner Ephraim Wernick is an expert in FCPA cases, having previously served in the criminal fraud and FCPA unit at the DOJ.
Michael Dry; Palmina Fava; Ephraim (Fry) Wernick ; Zachary Terwilliger
Joachim Alexander von der Goltz
Private Equity Fund
- Acted for Oracle in an investigation by the SEC for alleged violations of the FCPA.
- Assisted Oracle with compliance audits of its business partners in Argentina, Brazil, Central America, Mexico and the Caribbean.
- Represented a private equity fund in the risk assessment of an energy project in Brazil, including the evaluation of corruption and procurement fraud risks in a proposed transaction and joint venture.
Arnold & Porter has an impressive history in Latin America, which includes extensive geographic experience. This has provided a foundation for its well-established white-collar defence and investigations practice to build a solid Latin America-facing business, notably in internal investigations, government investigations, due diligence reviews and compliance, and risk assessment. The practice group features a number of former prosecutors and lawyers from the DOJ and SEC, and various of its practitioners are native or fluent Spanish and Portuguese speakers. Recent mandates saw the team continue to represent Samsung Heavy Industries in obtaining declinations from the DOJ related to a large FCPA case. New York’s Marcus Asner is a key partner with strong Latin America experience.
Marcus Asner; Amy Jeffress
Samsung Heavy Industries
- Represented Samsung Heavy Industries in obtaining declinations from the DOJ linked to a large FCPA case.
- Engaged by outside counsel for Israeli businessman Benjamin Steinmetz in English court proceedings to provide expert evidence on the FCPA and related issues under federal securities law and New York state law.
- Acted for CSL Behring in a challenge to a new CBP policy that bars Mexican nationals with B-1 business visas from entering the United States to donate blood plasma in exchange for payment.
Greenberg Traurig, LLP has a large white-collar defence and special investigations practice, while the firm has a lengthy history in Latin America. The firm represents a variety of multinationals and Latin American businesses, along with sovereign entities, government officials and senior executives, in connection with cross-border investigations, including allegations of FCPA violations. Notably, it advised the Bolivian government in US civil and criminal proceedings against a group of corrupt former officials that received bribes in exchange for lucrative weapons' purchase contracts. Washington DC partner Daniel Pulecio-Boek is a genuine Latin America white-collar defence and investigations specialist and has a blossoming reputation.
Antonio Peña; Marc Rossell; José Raz Guzmán
‘It is a very competent practice with deep knowledge of the American world and the Latin world.’
‘I highlight Daniel Pulecio-Boek. Firm, clear, secure, proactive, always available.’
‘The GT team is very good because of the constant monitoring of the issues, because they are attentive to the client and their needs. The team compares favorably because it is proactive and not reactive.’
‘The plus is precisely the personal relationship and the link with the local culture, its constant pursuit of the actions and its defense with the client. Daniel Pulecio is an extraordinary lawyer in that relationship of things. Ben Greenberg is a very knowledgeable criminal lawyer; and Jed Dier does very well in the Miami office. Tenacious and constant follow-up. Knowledge and explanation in lay and simple terms for the client.’
Agricultural Bank of China
- Represented Samar Handal, the main target at the center of the investigation into the assassination of the president of Haiti.
- Advised current and former executives and traders at Glencore in relation to a wide-ranging multi-jurisdictional Foreign Corrupt Practices Act (FCPA) case.
- Represented the Bolivian government in US civil and criminal proceedings against a group of corrupt former officials that received bribes in exchange for lucrative weapons contracts and against the weapons manufacturers and dealers who provided the weapons and paid the bribes.
Morrison Foerster has a sizeable investigations and white-collar defence practice that has strong links to Latin America. New York partner Ruti Smithline who was born and raised in Colombia - is co-chair of the investigations and white-collar defence practice group, and is also co-chair of the Latin America department. Her team has a prolific record in internal investigations, defending clients before the DOJ and SEC, third party and transactional due diligence, and compliance programmes and training. It also advised Odebrecht (now Novonor) on its compliance monitorship, following one of the largest FCPA settlements in history. Washington DC partner Charles Duross is co-chair of the investigations and white-collar defence practice group, and is a leader in FCPA cases.
‘We use MoFo for anti-corruption, sanctions and export controls advice, but also geopolitical country/sector assessments. MoFo is unique given the expertise they have in these fields, with many of the firm’s team members having a background as high ranking civil servants at the top authorities. MoFo stands out as they give legal but also commerical and pragmatic advice that can easily be implemented by corporate to assess and manage risks. The people that stand out are John Smith, Charles Duross and Nathanael Kurcab.‘
Odebrecht (now Novonor)
- Advised Odebrecht (now Novonor) on its compliance monitorship, following one of the largest FCPA settlements in history.
Steptoe & Johnson LLP
Steptoe & Johnson LLP is a big name in anti-corruption and FCPA cases and has experience of matters in a broad range of Latin American jurisdictions. It represents a large number of multinationals with interests in the region, along with a range of Latin American businesses - particularly Brazil-based organisations. The firm is also engaged by senior executives and individuals in the region. Lucinda Low is a prominent practitioner in FCPA and government investigations, and is a fluent Portuguese speaker having lived and worked in Brazil. Spanish speaker Brigida Benitez - a former Chief of the Office of Institutional Integrity at the IBD - is another experienced figure in anti-corruption matters and internal investigations, often involving the FCPA.
Lucinda Low; Brigida Benitez
Winston & Strawn LLP is a major force in corporate investigations and white-collar criminal defence, acting for both corporates and individuals. Coupled with this, the firm has a rapidly growing presence in Latin America matters, where it is increasingly active in cross-border investigations and enforcement cases. Along with anti-corruption matters, the firm is also building its standing in sanctions cases, including those under OFAC. The launch of a Miami office in May 2022 has significantly reinforced the firm’s reputation in Latin America and bolstered its contacts in the region. Abbe Lowell is a market leader in white-collar defence and has extensive experience in Latin America. San Francisco partner Pamela Davis heads the FCPA and anti-corruption team, and is another key figure for Latin America matters, as is Cari Stinebower, who previously lived and worked in Colombia.
Abbe Lowell; Suzanne Jaffe Bloom; Pamela Davis
Compagnie Maritime d’Affrètement and Compagnie Générale Maritime (CMA CGM)
Carlos Marcelino Bellosta Pallares
- Represented CMA CGM and its American subsidiary CMA CGM Americas, in defence of the plaintiffs’ litigation in Florida under Title III of the Helms Burton Act.
- Represented Carlos Bellosta, a former executive at Venequip, in the DOJ’s investigation into a kickback and bribery scheme involving Venequip and Venezuela’s state-owned and state-controlled energy company, Petróleos de Venezuela (PDVSA).