On March 30, 2015 the US Federal Bureau of Investigations (FBI) announced that it was establishing three dedicated International Corruption Squads, based in New York, Washington D.C., and Los Angeles. These Squads, comprising FBI agents, analysts, and other professional staff, will be responsible for investigating violations of the U.S. Foreign Corrupt Practices Act (FCPA) along with other bribery and money laundering offences and tracing and seizing the resulting proceeds. The establishment of these International Corruption Squads appears to have been spurred, at least in part, by the U.S. Government’s recent high profile enforcement of the FCPA and increased cooperation with its international counterparts. One FCPA settlement at the end of 2014, for example, cited cooperation with no less than nine other countries: Indonesia, Switzerland, the United Kingdom, Germany, Italy, Singapore, Saudi Arabia, Cyprus and Taiwan. The establishment of its International Corruption Squads demonstrates the FBI’s continued desire to proactively investigate international instances of corruption and the Fraud Section of the U.S. Department of Justice’s willingness to prosecute them. As well as targeting U.S. and multi-national companies as the payers of bribes, the FBI has expressed its intent to further target corrupt public officials abroad, and their illicit assets. The FBI seeks to forfeit the proceeds of corruption by foreign public officials and, where appropriate, use the recovered assets to benefit the people harmed by the acts of corruption. Through the establishment of its International Corruption Squads the FBI has drawn together its best expertise in these fields, to tackle both the demand and the supply of international bribery and better coordinate its end-to-end corruption investigations. The FBI’s press release on this initiative can be read in full here.
Geoff Martin is a Senior Associate at Baker McKenzie's Litigation and Government Enforcement practice group in Washington, DC. Geoff started his career in Baker McKenzie's London office in 2007 and moved to Washington DC in 2012. Geoff represents clients in matters before the federal government arising out of anti-corruption, trade sanctions, fraud, anti-money laundering, national security, and related enforcement actions. He also represents clients in civil and criminal matters in federal court. Geoff has extensive experience conducting internal investigations relating to such matters around the world.