GIR 100 2020

Willkie Farr & Gallagher

Professional notice

Willkie Farr & Gallagher recently secured a big win in representing Lebanese businessman Jean Boustani, who is the first defendant to defeat the DOJ's FCPA Unit at trial in several years. The firm also helped Barclays avoid charges in a blockbuster UK fraud case.

The firm

The firm had a standout year with the Boustani defence and more, including a landmark sanctions settlement and its representation of a Houston company in a prominent DOJ foreign bribery investigation.

In the past few years, the firm has helped its clients avoid prosecution in cases brought by the UK's Financial Conduct Authority and Serious Fraud Office (SFO), Department of Justice (DOJ) and Securities and Exchange Commission (SEC). In the Foreign Corrupt Practices Act space in particular, Willkie has helped a significant number of major companies accused of foreign bribery secure settlements with US authorities, including Daimler, Tyco, Pride International, Teva and Alcatel-Lucent.

Willkie's compliance and enforcement practice group is led by Martin Weinstein in Washington, DC. Weinstein is a former prosecutor with three decades of experience under his belt. As a young assistant US attorney in Atlanta, he led an investigation into whether aircraft manufacturer Lockheed (now Lockheed-Martin) had violated the FCPA by bribing officials in Egypt to win a contract. In 1995, the company was fined US$24.8 million - at that time the highest ever corruption fine.

Peter Burrell leads the litigation, compliance and enforcement, and white-collar defence practices in London. Also in London is US-qualified partner Rita Mitchell, who was named in GIR's Women in Investigations survey in 2017, and partner Simon Osborn-King, who was selected for the 2020 edition of GIR 40 under 40.

The securities enforcement practice boasts a strong cadre of former government officials - notably Elizabeth Gray, who was assistant director in the SEC's division of enforcement. Also on the team is Amelia Cottrell, who previously served as associate director of the SEC's New York Regional Office, and deals with regulatory investigations and compliance matters.

Willkie's white-collar defence practice group is led by Michael Schachter in New York and William Stellmach in Washington, DC.

Schachter and Stellmach are both former assistant US attorneys in the Southern District of New York, where Schachter notably prosecuted TV personality Martha Stewart in 2004. Stellmach also served as acting chief of the Fraud Section in the Criminal Division at Main Justice.

The firm hired partner Randall Jackson from Boies Schiller Flexner in New York in November 2018. The former assistant US attorney for the Southern District of New York focuses on investigations into bribery, corruption and money laundering.

In 2019, the firm hired Jay Martin as senior counsel in Houston. Martin was the associate general counsel and chief compliance officer at oil field services company Baker Hughes for 15 years.

Bruno Cova and Francesca Petronio joined Willkie in November 2019 in the Milan office. Cova has had a handful of in-house roles at prominent companies. GIR previously reported that Cova represents Anglo-Dutch oil company Shell in an ongoing high-profile bribery trial in Italy. Shell and its Italian business partner Eni are accused of bribing Nigerian officials for access to a lucrative oil field. Both companies deny wrongdoing.

The firm has six Who's Who Legal: Investigations nominees and two Who's Who Legal: Business Crime Defence nominees.

Recent events

Schachter and Jackson secured a big win for Lebanese businessman Jean Boustani in the first trial defeat for the DOJ's FCPA Unit in several years. After a six-week trial, a federal jury found Boustani not guilty in December 2019. US prosecutors had accused Boustani of defrauding US investors by carrying out and concealing a bribery scheme in order to secure loans for projects in Mozambique. Prosecutors claimed that US$2 billion in loans were sold to US investors who were unaware that at least US$200 million was diverted as bribes and kickbacks.

GIR reported that Willkie Farr helped UK financial institution Barclays avoid charges in a blockbuster UK fraud case over deals the bank arranged to raise billions in 2008. The ruling in the long-running case was handed down in 2018 and eagerly anticipated by the UK investigations bar for two years. The decision, which was made public in February 2020, clarified how the directing mind and will test can be applied to prosecute a company.

A Willkie team led by DC partner Michael Gottlieb is representing Houston-based oil company Citgo in a sprawling DOJ corruption investigation. The investigation, which Citgo is cooperating with, mainly focuses on bribes paid to officials at Citgo's parent company, the state-owned Petróleos de Venezuela SA (PDVSA). The company is also suing a Miami businessman who pleaded guilty to paying bribes to Citgo employees in exchange for contracts. Citgo is seeking compensation from the businessman, stating that, because of the bribery, it lost millions of dollars after paying inflated prices for goods and services on PDVSA's behalf.

GIR reported that partner David Mortlock guided a subsidiary of a UK cigarette manufacturer through a landmark settlement with US authorities in July 2020. The company, Essentra FZE, entered into the resolution for attempting to sell over US$300,000 in tobacco products to North Korea. The DOJ said the agreement is its first corporate enforcement action for breaches of the broad US trade restrictions that have been in place on North Korea since 2008.

A Willkie team led by Weinstein represented California-based networking products developer Juniper Networks in an FCPA investigation by the DOJ and SEC. The company settled the SEC investigation with a US$11.7 million civil resolution in August 2019 without admitting to misconduct. The DOJ dropped the case without enforcement action in February 2018.

The firm conducted an internal investigation for collapsed UK oil company Afren in 2014, focusing on allegations of fraud and money laundering by its former CEO and COO. The SFO charged Osman Shahenshah and Shahid Ullah in 2017 and a jury in London found the pair guilty in October 2018. Later that month, they were sentenced to a combined 11 years in prison.


Willkie has offices in Washington DC, New York, Houston, London, Paris, Brussels, Frankfurt, Milan and Rome. The firm recently launched a Chicago office.


Willkie Farr has built up an impressive client list, with on-the-record instructions from companies including networking products developer Juniper Networks and oil exploration business Afren.

Track record

A team of lawyers at Willkie Farr advised Israeli company Teva Pharmaceuticals, helping it through a foreign bribery investigation. In December 2016, the Israeli company agreed to pay a combined US$519 million in the US to settle allegations of bribery in Russia, Ukraine and Mexico. The DPA was dismissed in 2020 following the end of a successful monitorship.

The firm had a hand in the first ever FCPA-related DPA between an individual and the SEC. At the time, the SEC and DOJ were investigating allegations that software company PTC improperly provided recreational travel to Chinese government officials. In February 2016, partner Elizabeth Gray represented Yu Kai Yuan, a former PTC employee in China, in a settlement that deferred prosecution for three years, following his significant cooperation in the SEC's investigation.

Schacter represented former Rabobank traders Anthony Allen and Anthony Conti, who were convicted in 2015 for manipulating Libor. The pair appealed against the conviction to the US Court of Appeals for the Second Circuit in 2017 and were acquitted after successfully arguing that the use of compelled testimony violated their constitutional rights.

For more than 130 years, Willkie has provided strategic legal representation and trusted counsel to market-leading public and private companies and individuals around the world.  

Willkie’s elite international Compliance, Investigations & Enforcement practice is synonymous with high profile investigations, market leading enforcement actions and complex white collar cases. Our highly experienced team works on many of the largest, most complex and closely watched matters across the United States, United Kingdom and Continental Europe.  

We represent market leading companies, institutions and their executives across a wide range of business areas and industries in all aspects of compliance, investigations and enforcement. The cases we handle often involve multijurisdictional aspects, complex legal and factual issues and novel areas of law. Our bench is unparalleled and is one of the strongest and deepest in the market, comprising of lawyers who are among the most highly skilled in their fields and who are renowned for their judgement and clear advice. The majority of our partners have prior government experience, including one who was the former White House sanctions advisor, two who held senior positions at the SEC, and six who served as federal U.S. prosecutors.   

Over the past 12 months, our team has handled an array of notable investigations and trials of the highest commercial significance. Matters include a major victory in a securities fraud trial, a sanctions case in relation to North Korea, and successfully defending a global financial institution against criminal charges brought by the SFO in what was the first ever attempted corporate prosecution of a major UK bank.  

We continually receive market recognition for the work we do and are proud to have been awarded “Most Impressive Investigations Practice” and “Most Important Court Case” by GIR Awards 2020. Our innovative team is also highly regarded for its experience and client service in all the industry-leading legal directories.  

In 2019, we launched the Willkie Compliance Concourse app which offers legal and compliance teams free, on-demand access to comprehensive practical guides, real-time news and analysis, and CLEs covering a range of matters. In the last year, the number of active users per month has increased by more than 125% and in total, the app has had nearly 39,500 users since launch. 

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