FCPA Enforcement Actions and Compliance Guidelines: Recent Trends and Patterns

Rajal Dubal is a Senior Managing Director at Ankura based in New York.  She brings over 25 years of experience in independent corporate investigations, anti-money laundering and sanctions, applied analytics, financial accounting and reporting, transactional advice, and auditing. Rajal specializes in conducting fraud and anti-corruption investigations.  She is an expert at assessing accounting systems and corporate control environments and implementing creative solutions to help her clients fill gaps and weaknesses in controls that led to investigations. Rajal also brings her expertise to financial institutions in the areas of compliance testing, AML and sanctions transaction monitoring, lookbacks, model validations and tuning, data governance, and anti-bribery enhancements to KYC platforms. Rajal combines her forensic accounting and operational expertise to help clients develop solutions to improve anti-corruption and anti-money laundering controls. 

Kathleen focuses on white-collar criminal defense including anti-corruption investigations and compliance counseling, complex commercial litigation, and cross-border investigations and disputes.  As a senior associate based in the Washington, D.C. office, Kathleen has experience counseling clients facing investigations before the U.S. Department of Justice and the Securities and Exchange Commission, as well as other domestic and international authorities.  She also handles cases for clients in high-stakes adversarial proceedings, including trial-level litigation and arbitrations.

Kathleen represents companies across the globe in high-stakes matters.  She has handled investigations and enforcement actions in North America, South America, Europe, the Middle East, and Asia.  Kathleen is also experienced in all aspects of compliance counseling, including compliance assessment, remediation, and data privacy considerations.

Jennifer D. Riddle is of counsel in the Litigation practice of Paul Hastings and is based in the firm’s Washington, D.C. office. Her practice focuses on compliance with and disputes relating to the U.S. Foreign Corrupt Practices Act (“FCPA”) and other international anti-corruption laws.

Ms. Riddle conducts internal investigations on behalf of senior management, boards of directors, and audit committees with respect to the FCPA, international anti-corruption laws, fraud, and kickbacks. She has acted as the senior associate leading investigations in Europe, Africa, Asia, and the Middle East.

Ms. Riddle designs and implements comprehensive anti-corruption compliance programs that are tailored to the client’s particular risks and provides compliance training to senior management, in-house lawyers, sales and marketing personnel, internal auditors, and third parties. Ms. Riddle handles due diligence of third party representatives, business partners for joint ventures, teaming arrangements and alliances, and other third party service providers, as well as targets in mergers and acquisitions. Ms. Riddle conducts risk assessments and advises on anti-corruption audits. Ms. Riddle has also advised and acted as the primary liaison with respect to an independent corporate monitor stemming from an FCPA settlement.