Webcast: Ten Years After Siemens: The Evolving Landscape of Global Anti-Corruption Enforcement

September 17, 2018

Ten years have passed since the watershed Siemens resolution with the DOJ, SEC, Munich Public Prosecutor and World Bank in December 2008. Over the last decade, global anti-corruption enforcement and multinational cooperation has taken off. Numerous jurisdictions have developed internal frameworks to facilitate anti-corruption enforcement. Governments routinely share information during investigations, and there is an emerging trend of credits, discounts and multi-jurisdictional settlements. The road to such resolutions however is neither easy nor settled. This webcast will discuss the many issues that arise during these complex multijurisdictional investigations and offer some strategic guidance for avoiding pitfalls and challenges that can occur. Listen and interact with questions to five Gibson Dunn partners who have held central international roles in either enforcement agencies or private practice and have significantly contributed to the shape of that landscape and the writing of its history.

Topics to be covered:

  • Anti-corruption enforcement in the United States
  • Key multinational enforcement efforts, anti-corruption frameworks and global cooperation approaches
  • Mitigation strategies to avoid duplicative investigations and resolutions
  • Expectations for the future

View Slides [PDF]


Richard Grime is a partner in Gibson Dunn’s Washington, D.C. office and Co-Chair of the firm’s Securities Enforcement Practice Group. Mr. Grime’s practice focuses on representing companies and individuals in corruption, accounting fraud, and securities enforcement matters before the SEC and the DOJ. Prior to joining the firm, Mr. Grime was Assistant Director in the Division of Enforcement at the SEC, where he supervised the filing of over 70 enforcement actions covering a wide range of the Commission’s activities, including the first FCPA case involving SEC penalties for violations of a prior Commission order, numerous financial fraud cases, and multiple insider trading and Ponzi-scheme enforcement actions.

Sacha Harber-Kelly is a partner in the Dispute Resolution Group of Gibson Dunn’s London office, where he specializes in global white-collar investigations. Prior to joining the firm in January 2018, Mr. Harber-Kelly was a prosecutor in the Anti-Corruption and Bribery Division at the U.K.’s Serious Fraud Office. He had central involvement in each of the U.K.’s simultaneous global corporate corruption resolutions whether by prosecution, civil asset recovery or Deferred Prosecution Agreement (DPA). He was equally involved in the U.K.’s development of its DPA regime, writing its governing Code of Practice and prosecuting both the first such resolution and latterly the largest and most complex.

Benno Schwarz is a German-qualified partner in Gibson Dunn’s Munich office and a member of the firm’s International Corporate Transactions and White Collar Defense and Investigations Practice Groups. Mr. Schwarz has many years of experience in the area of corporate anti-bribery compliance, especially issues surrounding the enforcement of the US FCPA and the UK Bribery Act as well as applicable Russian law. Mr. Schwarz was a member of the international team from Gibson Dunn advising the Siemens compliance monitor, the first non-U.S. compliance monitor in conjunction with the world’s largest FCPA settlement to date.

Patrick Stokes is a partner in Gibson Dunn’s Washington, D.C. office, where his practice focuses on internal corporate investigations and enforcement actions regarding corruption, securities fraud, and financial institutions fraud. Prior to joining the firm, Mr. Stokes headed the DOJ’s FCPA Unit, managing the FCPA enforcement program and all criminal FCPA matters throughout the United States covering every significant business sector. Previously, he served as Co-Chief of the DOJ’s Securities and Financial Fraud Unit.

F. Joseph Warin is a partner in Gibson Dunn’s Washington, D.C. office, Chair of the office’s Litigation Department, and Co-Chair of the firm’s White Collar Defense and Investigations Practice Group. Mr. Warin is regarded as a top lawyer in FCPA investigations, FCA cases, and special committee representations. He has handled cases in dozens of countries in matters involving federal regulatory inquiries, criminal investigations and cross-border inquiries by dozens of international enforcers, including UK’s SFO and FCA, and government regulators in Germany, Switzerland, Hong Kong, and the Middle East.