FCPA
USA
9 years ranked
Provided by WilmerHale
Erin Sloane's practice focuses on government and internal investigations and white collar criminal matters, with a concentration on Foreign Corrupt Practices Act (FCPA) and international anti-corruption issues. She has successfully represented both institutions and individuals in government investigations and prosecutions involving financial and accounting fraud, insider trading, wire fraud, and FCPA issues.
Ms. Sloane has conducted numerous cross-border corruption investigations in Asia, Eastern Europe, the Middle East and South America, and regularly appears before the US Department of Justice (DOJ) and Securities and Exchange Commission (SEC) in corruption-related investigations. She has successfully achieved multiple non-public DOJ and SEC declinations for clients in FCPA matters and has advised several prominent clients as they have worked to meet the terms of their publicly disclosed FCPA resolutions with the DOJ and SEC. Ms. Sloane also regularly counsels clients on challenging anti-corruption issues in numerous business contexts, including the development and implementation of effective anti-corruption compliance programs and corruption-related considerations in cross-border mergers, joint ventures and acquisitions.
Since June 2023, Ms. Sloane has led a team representing the firm’s long-time client, Glencore, in connection with two independent compliance monitorships imposed by DOJ in connection with coordinated resolutions with the FCPA and MIMF units of the Department in May 2022. In March 2025, the DOJ determined that it was appropriate to terminate those monitorships 15 months before the three year term was set to end. This unprecedented decision marked the first time the DOJ cut short a compliance monitorship by invoking a standard provision in plea agreements allowing for the modification of probation conditions.
In August 2019, the DOJ and SEC appointed Ms. Sloane as the independent FCPA compliance monitor for a German-based global healthcare company with a market cap of $24 billion. Ms. Sloane is one of only a handful of lawyers who have not previously served in Government to obtain such an appointment.
Ms. Sloane is one of the founders of the Innocence Project’s Young Professionals Committee (YPC)—a group of young professionals dedicated to supporting the Innocence Project through fundraising and community outreach efforts. Ms. Sloane is also actively involved in WilmerHale’s Women’s Leadership Initiative.
Strategies For Navigating Compliance Monitorships - Law360
The Guide to Anti-Money Laundering: Money Laundering and International Corruption - Global Investigations Review’s (GIR)’s The Guide to Anti-Money Laundering
WilmerHale Team Updates Essential Foreign Corrupt Practices Act Treatise - Complying with the Foreign Corrupt Practices Act - 10th Edition
Ms. Sloane has played key roles in numerous investigations by the DOJ and SEC, as well as many corporate internal investigations, and has led global FCPA due diligence reviews in several multi-billion-dollar M&A transactions. She has also been involved in securing a number of nonpublic prosecution declinations by the DOJ and SEC in connection with possible FCPA violations by various multinational clients. A select list of her recent experience includes:
securing a 15-month early termination of two 3-year compliance monitorships imposed on Glencore as part of its $1.1 billion plea agreement for bribery and market manipulation with the DOJ and CFTC. This unprecedented decision marked the first time the DOJ cut short a compliance monitorship by invoking a standard provision in plea agreements to modify probation conditions;
serving as the DOJ/SEC appointed independent FCPA compliance monitor for a German-based supplier of global dialysis products and services in connection with the company’s $231 million resolution of charges that it violated the FCPA;
representing a major foreign technology conglomerate in ongoing SEC and DOJ investigations into allegations of FCPA violations at a US-based avionics subsidiary;
representing a major media and communications company in connection with the successful resolution of the US Attorney for the Eastern District of New York's investigation into its Argentine joint venture's role in the FIFA corruption scandal;
representing a multinational industrial company in an investigation of self-disclosed alleged FCPA violations related to its China-based marine business, resulting in a successful settlement from the SEC and a declination from the DOJ;
securing a favorable SEC settlement and DOJ declination on behalf a US-based oilfield services company in connection with a global FCPA investigation involving allegations of improper payments to a Mexican foreign official;
representing a major multinational industrial conglomerate in a DOJ and SEC investigation into government sales in the Middle East, resulting in non-public declinations from both agencies;
leading a global due diligence review of more than 150 third-party advisors in more than 30 countries in connection with a criminal investigation of a large defense contractor and manufacturer by the DOJ and UK Serious Fraud Office;
representing a major US multinational industrial conglomerate in pre- and post-close due diligence investigations of an acquisition target, ultimately resulting in non-public declinations from both the DOJ and SEC;
representing a global manufacturer in resolutions with the DOJ, SEC, Department of Treasury and Department of Commerce of charges relating to improper kickbacks under the United Nations Oil-for-Food Program, violations of the FCPA and violations of US export laws;
representing a major Wall Street broker dealer in connection with parallel criminal and civil investigations of a former bond trader;
representing an international financial services firm in an insider trading prosecution of a former investment bank employee;
representing a former Congressman and Reagan budget director in connection with parallel civil and criminal securities and accounting fraud cases, including successfully obtaining a nolle prosecui of the criminal indictment; and
participating in a secondment to the internal investigations group of a multinational pharmaceutical corporation.
New York University School of Law
JD
2003
University of Virginia
BA
1998
Notable Woman in Law
Crain's New York Business
2021
40 Under 40
Global Investigations Review
Rising Star
New York Law Journal
2014
Advocate for Justice Award
the Innocence Project
2011
Provided by Chambers
Provided by Chambers
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