Law Offices of Patrick M. Norton

         ANTI-CORRUPTION

Mr. Norton has extensive experience advising clients on compliance with the United States Foreign Corrupt Practices Act (“FCPA”) and related international anti-corruption laws.  He has supervised several multinational FCPA investigations for US and UK clients and has coordinated those investigations with parallel investigations by the United States Department of Justice, the United States Securities and Exchange Commission, and local law enforcement authorities in third countries.  Mr. Norton has also conducted more than 20 internal FCPA investigations principally involving compliance with anti-corruption laws in China and other Asian countries.  Mr. Norton regularly counsels clients on anti-corruption compliance programs and on anti-corruption due diligence in M&A transactions.  He has chaired or addressed numerous anti-corruption conferences in the United States, Europe, and Asia.



Representative Matters

  •     Advised the Board of Directors of a NYSE-listed company in an investigation of the company’s sales in more than 20 countries in Europe, Asia, and Latin America for compliance with the FCPA.  Coordinated the company’s investigation with parallel US Government investigations.  The company settled with the DOJ and SEC in 2014.
  •    Advised the Board of Directors of a FTSE-listed UK company in the investigation of a US subsidiary’s sales in more than 30 countries in Europe, the Middle East, Asia and Africa for FCPA compliance.  Negotiated settlement of all US charges against the company in 2012 and coordinated responses to inquiries from customers and governments in other countries.  Advised the company during criminal investigations and prosecutions of former employees by the US Government.
  •    Conducted more than 20 internal corporate investigations of FCPA compliance issues in China, India, Korea, Vietnam and other Asian countries.
  •    Advised numerous clients on setting up and implementing anti-corruption compliance programs worldwide.
  •    Advised numerous clients on anti-corruption due diligence in M&A transactions in various countries.


FOR PUBLICATIONS AND SEMINAR PRESENTATIONS CONCERNING ANTI-CORRUPTION TOPICS, SEE SUB-HEADING: ANTI-CORRUPTION PUBLICATIONS AND SEMINARS