Weil Gotshal & Manges

Weil Gotshal’s FCPA team is led by Steven Tyrrell, a former chief of the fraud section in the DOJ’s criminal division. Serving in that position from 2006 to 2009, Tyrrell oversaw the explosion in foreign bribery enforcement that began under Mark Mendelsohn, the section deputy chief that put the statute on corporate America’s radar.

Tyrrell supervised the hiring of several prosecutors to manage the new workload, and helped establish an inter-agency healthcare fraud task force led by Kirk Ogrosky, now a partner at Arnold & Porter. It was during this time that the section began developing the foundational principles of its anti-corruption enforcement regime, including corporate penalties calculated based on sentencing guidelines and a focus on individual prosecutions. 

Tyrrell was recruited to Weil Gotshal in early 2010 by William Burck, who later left the firm to join Quinn Emanuel Urquhart & Sullivan. At Weil, Tyrrell has built a strong white-collar practice, which consists of about 12 lawyers who work on FCPA matters. Other prominent practitioners include litigation partner Holly Loiseau and counsel Adam Safwat, a former FCPA prosecutor who served as a deputy chief of the criminal division’s fraud section from 2012 to 2014.

In the past four years, Weil Gotshal has secured a steady flow of FCPA-related work. The firm represents French pharmaceutical company Sanofi in relation to ongoing DOJ and SEC investigations into allegations of bribery involving healthcare professionals in various emerging markets, including in the Middle East and Africa, according to securities filings.

The firm advises offshore drilling contractor Vantage Drilling in an investigation into the company’s relationship with Brazilian oil and gas company Petrobras, and Innodata, a New Jersey-based information technology company, which in May disclosed potential FCPA violations by employees of a foreign subsidiary in connection with an inspection of the subsidiary's compliance with local tax requirements. It also secured a declination from the DOJ and SEC for an Indian company, which acted as a local agent of US coal mining equipment manufacturer.

Weil Gotshal has also represented a handful of individuals in FCPA matters. The firm has advised Mario Lopez Estrada, a Guatemalan businessman and investor, following a self-disclosure to the DOJ by telecoms company Milicom, relating to possible bribes made on behalf of Guatemala's largest mobile telecoms provider.

It also represents two senior Wal-Mart executives in relation to DOJ and SEC’s ongoing probe into the company’s operations in various countries, including Mexico, Brazil, India and China; a senior investment banker of Morgan Stanley in relation to investigations into the bank’s hiring practices; and three senior executives of Teva Pharmaceuticals, which received a subpoena from the SEC in 2012 over alleged FCPA violations in Russia and Latin America.

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