Sidley lawyers have extensive experience in conducting internal investigations for major U.S. corporations, both in the United States and abroad, including in China, Korea, Hungary, Lithuania, Bulgaria, Thailand, Poland, Italy, Philippines, India, Venezuela and Brazil. Sidley’s team includes many former federal prosecutors and SEC enforcement lawyers.
Sidley lawyers have conducted investigations involving the Foreign Corrupt Practices Act, healthcare fraud, FDA violations, executive improprieties, insider trading, market manipulation, accounting fraud, defense procurement/government contracting fraud, environmental violations and many others.
When conducting investigations, Sidley lawyers often advise companies on corporate governance issues and compliance programs. The team has the ability to call on other Sidley lawyers with regulatory experience in virtually every substantive area of law.
Members of the Sidley team have conducted the following representative sample of internal investigations:
- Represented a special committee of a major airline regarding an investigation into the Company’s operation of certain aircraft, its maintenance program, and related FAA issues.
- Performed investigations for special committees of multiple oil and gas companies regarding accounting practices, policies, and procedures in light of accounting irregularities that led to financial restatements.
- Represented a geophysical company in an investigation into directors’ exercise of fiduciary duties in voting to approve a commercial transaction with another company in the industry.
- Represented a special committee of an international energy company in connection with an investigation regarding allegations of FCPA violations in multiple countries.
- Taken the lead in working with World Bank lawyers and investigators to uncover and prosecute fraud, bid-rigging and public corruption involving Bank-funded projects worldwide.
- Developed facts and evidence necessary to work with law enforcement to assist clients who have been victimized by fraud to obtain restitution and recovery of assets, including the recovery of $60 million for bank clients victimized by a lending scheme, which was nearly all of the money that our clients lost.
- Led investigations involving novel charges of improper pharmaceutical sales and promotional practices for some of the world’s largest drug companies.
- Reviewed suspected accounting irregularities on behalf of a retail drugstore chain in one of the most significant financial accounting scandals.
- Investigated potential civil and criminal environmental matters in a wide range of settings from heavy manufacturing industries, railroads, utilities and construction projects to waste disposal companies and cruise lines.
- Represented an international bank in an internal investigation related to one of the largest European corporate frauds in history, involving over $10 billion in losses, which included coordination with multiple domestic and foreign regulatory and law enforcement bodies.
- Investigated allegations that a gas utility had defrauded its customers by manipulating the rate-making system.
- Investigated fraud allegations for several hospitals and managed care plans.
- Performed internal investigations for large international companies in Poland, Brazil, Egypt, China, India, Korea, Philippines, Hungary, Italy, Bulgaria and other countries in response to allegations of bribery of government officials.
- Investigated allegations of insider trading by employees at a global insurance firm and at a national retail department store chain.
- Represented a major insurance company in an internal investigation concerning potential round trip fund transactions.
- Represented a major retail company in an internal investigation of stock option grant practices.
- Represented a Fortune 500 manufacturing company in an internal investigation of information sharing with numerous competitors.
- Represented a Fortune 500 manufacturing company in internal investigations regarding employment practices.
- Represented a major communications company in an internal investigation of telecommunications fraud.
- Represented a publicly traded real estate company in an internal investigation of alleged insider trading by a former member of senior management.
- Represented a multinational commodity trading corporation in an internal investigation of executive compensation issues and related party transactions.
- Represented a U.S.-based insurance company in an internal investigation of an anonymous complaint regarding its Brazilian subsidiary’s accounting treatment of certain litigation-related reserves.
- Represented a Mexican conglomerate in an internal investigation of potential U.S. securities laws violations in connection with that corporation’s acquisition activities in Mexico and the U.S.
- Represented a multinational shipping company in an internal investigation of alleged misconduct in procurement and award of contracts.
- Represented a telecommunications company in an internal investigation of accounting issues regarding reserves.
- Represented a financial services company in an internal investigation of alleged insider trading by hedge fund clients.
- Represented a retailer in an internal investigation of alleged accounting fraud through the capitalization of information technology expenses.
- Represented a waste management company in an internal investigation of alleged misconduct by officers and tax violations.
- Represented an aircraft manufacturer in an internal investigation of alleged money laundering issues in Mexico.
- Represented a consumer products and food company in connection with an internal investigation of alleged environmental violations.