The White Collar Defense and Investigations Practice Group regularly conducts sensitive internal investigations of potential wrongdoing for corporations, board audit committees, special committees and general counsels. We proceed with discretion, but thoroughly, to gather and analyze data from individuals and documents on claims of:
- Illegal bribes
- Insider trading
- Breaches of fiduciary duty
- Accounting irregularities
- Money laundering
- Network misconduct and theft of trade secrets
- Violations of government contract regulations
- Health care fraud
- Violations of the U.S. Foreign Corrupt Practices Act
We make independent assessments and recommendations to our clients, recognizing that early and aggressive crisis management can enhance a corporation's credibility with law enforcement officials, regulators and the investment community and eliminate or mitigate exposure.
The White Collar Defense and Investigations group conducts sensitive internal investigations with discretion and thoroughness.
While many of our engagements in this area cannot be made public, recent representations include:
- Retained by the Office of the Governor of New Jersey, in response to a U.S. media firestorm and related criminal and legislative investigations, to conduct a comprehensive internal investigation related to (i) allegations concerning the George Washington Bridge toll lane realignment at Fort Lee, New Jersey, and (ii) the Hoboken Mayor's allegations concerning Superstorm Sandy aid allocations to the city of Hoboken. During a compressed two-month period, the Gibson Dunn team interviewed over 70 witnesses and reviewed more than 250,000 documents. In addition to responding to subpoenas from the U.S. Attorney's Office for the District of New Jersey and the New Jersey Legislative Select Committee on Investigation, Gibson Dunn prepared an exhaustive 344-page report of its findings and recommendations. That report was publicly released, along with numerous underlying exhibits and materials, including the internal memoranda of interviews. The public release of the Gibson Dunn report was accompanied by a press conference carried live on numerous television channels with additional follow-on media appearances and interviews. Gibson Dunn continued its representation of the Office in response to subsequent related inquiries.
- Conducting investigations for several multinational companies into whistleblower complaints regarding conduct in Russia and Eastern Europe.
- Guiding Hewlett-Packard through a major government and internal investigation regarding allegedly improper business practices spanning Russia, Eastern Europe and the Commonwealth of Independent States (CIS).
- Investigating potentially improper payments allegedly made by a large international engineering company in connection with bids for various development contracts in Southeast Asia.
- Conducting investigations for a large U.S. international construction and engineering company into alleged improper payments made in connection with bids for various government contracts in the Middle East.
- Representing a large Dutch company in an internal investigation involving potentially improper payments to government officials in Southeast Asia.
- Advising a large U.S. pharmaceutical company with respect to an investigation involving potentially improper payments to government officials in India.
- Conducting a significant internal inquiry for a corporate client relating to Office of Foreign Assets Control (OFAC) sanctions enforcement issues, an inquiry that involved work in the United States, Europe and Asia.
- Conducted an internal investigation on behalf of the audit committee of a Fortune 50 company concerning senior-executive-compensation-related issues.