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Notable Anti-corruption Compliance Matters

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Along with Skadden, Arps, Slate, Meagher & Flom, conducted a comprehensive review of risks under Vietnamese criminal laws and anti-corruption laws in relation to a proposed US Department of Justice (DOJ)/Securities & Exchange Commission (SEC) settlement agreement with a multinational client. The settlement agreement revealed potentially prohibited acts in Vietnam. The review included an assessment of Vietnamese anti-corruption law, potential liabilities, applicability of reporting requirements, risks to the client’s other business interests in Vietnam, and possibilities for risk mitigation.

Collaborated with Willkie Farr & Gallagher LLP to address a proposed Tet gift program under Vietnamese anti-corruption laws, focusing on permissible values for gifts and exceptions.

Worked with Willkie Farr & Gallagher LLP to evaluate unique payment and delivery arrangements proposed by individuals acting for a Vietnamese military unit to determine compliance with Vietnamese government procurement law.

Reviewed Vietnamese law governing whistleblowing (including privacy rules), interviewed two specific whistleblowers in two different matters, evaluated information, and reported to the client in the US, providing guidance to the client.

Advised US defense counsel pro bono on the definition of “public officials” under Vietnamese law in connection with charges brought in the US against several individuals for alleged violations of the FCPA in Vietnam.

Conducted two separate extensive investigations of bribery within the same company, one involving the Managing Director, working with both regional and headquarters counsel.

Assisted an unnamed international bank in determining the legitimacy of certain internal transactions.

Revised corporate Code of Conduct and created a manual on investigation, retention, and payment of third-party consultants, including guidelines on gifts, travel, and reimbursements.

Examined a proposed incentive program used to reward customers’ employees with a rebate (based on the customer’s purchases) under both the FCPA and Vietnamese anti-corruption laws.

Acted in several separate matters for multinationals that investigated employees (in one case, for unauthorized payment to government officials and in another case for price fixing with distributors). In a third case, investigated allegations that a sales team deviated from company policy by favoring certain distributors. Employees were questioned directly with the client’s verbal, forensic input.

Acted for an international bank to examine specific payments made by internal staff to assess whether payments violated Vietnamese anti-corruption law. Also, assessed whether receipts issued by government offices against receipt of payment overcome any legal issues that the payment may raise.

Drafted appropriate FCPA language for contracts, employment agreements, responded to numerous hypothetical fact situations, provided training for foreign and Vietnamese companies and business groups, and participated in panels involving presentations on Vietnam corruption issues.

Delivered general FCPA presentations and provided training to individual clients and to the business community in both HCM City and Hanoi.

Provided basic FCPA training to Vietnamese company employees soon after it was acquired by an American company and did so based on the client’s code of conduct.

Reviewed the obligations of a foreign enterprise in Vietnam to report a bribe about which it became aware, outlining procedures for doing so under Vietnamese criminal and anti-corruption laws.

Conducted due diligence on target companies before acquisition to assess the possible existence of any pre-acquisition corrupt practices.

Prepared a comprehensive review of anti-money laundering rules then in force in Vietnam.

Provided a full review of internal policies and converted informal guidelines into a consistent, written format.

Provided language for Employee Certification of FCPA compliance.

Assessed whether a corporate practice of making monthly payments to a customs broker, ultimately used as facilitation payments to various customs department employees, violated Vietnamese anti-corruption laws.

Conducted a general overview of compliance with FCPA regulations, paying particular attention to identifying and addressing red flags.

Collaborated with a firm conducting financial due diligence in an M&A transaction. In connection with the investigation, identified specific areas of potential concern related to the proposed acquisition of an entity.

Prepared template Contract Terms on FCPA compliance for contracts with Vietnamese representatives and agents.

Reviewed a plan to offer accommodations at the client’s hotel to a group composed of Vietnamese state officials and employees at reduced rates (i.e., at the client’s standard Government Employee Rate) as well as complimentary beverages and snacks.

Evaluated risks under FCPA regulations of forming a Teaming Agreement between the client and a Vietnamese company to participate in a bidding package run by a state-owned enterprise, where the state-owned enterprise owned a controlling stake in the Vietnamese company.

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