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REPRESENTATIVE EXPERIENCE

Brian F. Saulnier

Led an internal investigation into alleged Foreign Corrupt Practices Act (FCPA) violations at a Chinese subsidiary of Nortek, Inc. (Nortek), a U.S. public company. The team guided Nortek through the process of self-reporting the matter to the Securities and Exchange Commission (SEC) and the Department of Justice (DOJ) and then represented the company in the ensuing resolution. Nortek entered into a rare SEC Non-Prosecution Agreement (NPA) and the DOJ announced publicly its decision to decline to prosecute, the first settlement under the so-called DOJ “Pilot Program.”
Conducting an internal investigation for a SE Asia-based, publicly-traded, global manufacturer of marine and offshore integrated solutions into allegations of corrupt payments to government officials and others in Brazil, in connection with “Operation Car Wash,” and representing that manufacturer before various governmental agencies.
Conducted a multi-jurisdiction, cross-border internal investigation for a Fortune 200 company operating in the upstream oil and gas sector into allegations of corrupt payments by third parties to customs officials of a West African nation, in violation of the FCPA and UK Bribery Act.
Conducted an internal investigation from 2018-2019 for a global supplier of paint, coatings, and specialty materials regarding allegations related to two of the client’s former employees and three of the client’s customers. The investigation stemmed from payment of an administrative penalty to a government agency for violation of PRC laws. The allegations suggested violations of the FCPA and applicable People’s Republic of China (PRC) anti-corruption laws.
Conducted a multi-jurisdiction, cross-border internal investigation on behalf of a special committee of independent directors of a privately-held, U.S.-based, global law enforcement equipment supply contractor into allegations of corrupt payments to U.N. officials and foreign officials in Europe, South America, and the Middle East by a senior employee and certain international sales agents. The investigation resulted in real-time, ongoing self-reporting to the DOJ and SEC, and ultimately resolved in settlement.
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