Cadwalader Wickersham & Taft

Cadwalader’s FCPA practice was founded in 1991 by Ray Banoun, now special counsel for the firm, whose anti-corruption expertise stretches back to the law’s earlier days.

Banoun first prosecuted FCPA cases while at the US Attorney’s Office for the District of Columbia, and later handled several foreign bribery cases after leaving for private practice to Arent Fox. When FCPA enforcement exploded in the mid-2000s, Cadwalader was ready to take advantage. The firm represented the Virginia-based electricity company AES in relation to a DOJ probe into the Bujagali Dam project in Uganda. Involving collaboration between the Justice Department and the UK’s Serious Fraud Office, the case was emblematic of the new era of aggressive anti-corruption enforcement. 

The firm’s FCPA capabilities soon grew with the addition of Bret Campbell, who joined from Clifford Chance, and Peter Clark, who moved from the DOJ criminal division’s fraud section, where he served as a deputy chief and oversaw early enforcement of the 1977 anti-bribery statute. Previously, Clark also served as senior litigation counsel and a special counsel in the SEC’s enforcement division.

Other prominent recruits include Jodi Avergun, a former assistant US attorney in the Eastern District of New York, who joined the firm in 2007, and Kenneth Wainstein, a former US Homeland Security advisor to then-president George W Bush. Wainstein, who was appointed in 2006 as the first assistant attorney general for national security and in 2004 as the US attorney in Washington, DC, now heads the firm’s white-collar and investigations group.

Cadwalader’s practice is focused almost entirely on corporations. Banoun represents construction and civil engineering company Bechtel in connection with the prosecution of the former manager of a joint venture between the company and Egypt’s state-owned electricity company. The manager, Asem Elgawhary, pleaded guilty in December 2014 to taking US$5.2 million in kickbacks to rig bids for state-run power contracts. Bechtel was not charged in relation to the investigation.

Campbell has advised Pfizer, which in 2007 settled FCPA charges with a deferred prosecution agreement and paid US$15 million in criminal fines and US$26.3 million in civil disgorgement.

The firm also represented oil and gas services provider Vetco International, Schnitzer Steel and the audit committee of the London-based offshore drilling company Noble Corporation. Cadwalader was co-counsel to Hungarian telecommunications company Magyar Telekom in various foreign bribery investigations.

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