Iris Bennett

Practice Areas

Ms. Bennett has deep experience counseling clients on the investigation, defense, and resolution of white collar matters, as well as the corporate compliance programs designed to avoid such liabilities. She has represented numerous Fortune 100 corporate and individual clients in matters relating to potential violations of criminal or civil fraud statutes, including the Foreign Corrupt Practices Act, the False Claims Act, the Anti-Kickback Act, and antitrust laws. She has also represented companies in matters implicating the federal mandatory and voluntary disclosure rules and brought those matters to successful resolution. She has conducted internal investigations in cases across the globe and represented companies before the Criminal and Civil Divisions of the Department of Justice as well as the Securities and Exchange Commission, in all phases of U.S. government investigations and settlement. Ms. Bennett’s fluency in Spanish has enabled her to conduct many investigations in that language.

She serves as Independent Compliance Monitor for SNC-Lavalin Group, Inc. on behalf of the International Bank for Reconstruction and Development and International Development Association (World Bank) with a mandate to review and evaluate the company's global anti-corruption compliance program. Ms. Bennett also regularly advises corporate clients on their anti-corruption compliance programs and on specific policies, procedures and compliance questions and has designed and led large-scale corporate compliance reviews and audits. Ms. Bennett, Joseph Covington and Carlos Grover have served as Counsel to the Special Committee of the Board of Directors of Petróleo Brasileiro S.A. (Petrobras), a Committee formed to provide independent oversight of the Company’s internal investigation and remediation in connection with the “Lava Jato” matter. Click here for a link to the press release announcing the formation of the Special Committee.

Ms. Bennett clerked for the Honorable Robert W. Sweet of the United States District Court for the Southern District of New York, and for the Honorable David S. Tatel of the United States Court of Appeals for the District of Columbia. Ms. Bennett entered private practice after serving as a federal criminal defense lawyer in the District of Columbia Federal Public Defenders’ office.

Professional Memberships

Public International and Criminal Law Subcommittee for the District of Columbia Bar, International Law Community, Co-Chair

Women’s White Collar Defense Association, Co-Chair of the Chapter Subcommittee

WWCDA Chapter Launches Subcommittee, Member

National Association of Criminal Defense Lawyers (NACDL), White Collar Committee, Member

Publications

Expert Analysis, FCPA Disgorgement: Putting SEC To Its Burden Of Proof, Law360 (August 4, 2017)

Expert Analysis, The 9th Circ.'s Expansive Reading Of Escobar In Gilead, Law360 (July 26, 2017)

Author, Practicing Under the U.S. Anti-Corruption Laws, Aspen Book Publishers, 2013 Edition, May 2013 FCPA Compliance and Enforcement Trends Annual Guide (published annually).

Experience

- Investigation on behalf of an Independent Committee engaged by the Board of Directors of Vale, S.A., into the causes and responsibilities for the January 2019 Brumadinho tailings dam failure. This high-profile matter received close scrutiny from company stakeholders, outside auditors, criminal and civil enforcement agencies, the federal and state legislative bodies, victims’ families, the mining industry, and the Brazilian public. Vale, S.A., published an Executive Summary of the Independent Committee’s report in February 2020 on the core investigation findings and forward-looking recommendations of the Independent Committee, and has provided public progress updates on the status of implementing these recommendations.

- Leading an independent compliance monitorship for the World Bank of SNC-Lavalin Group Inc., with a mandate to review and evaluate the company’s global anti-corruption compliance program.

- Representation of a multinational defense industry company in a voluntary disclosure to the State Department, DOJ, and SEC, regarding entertainment of foreign officials. A declination was obtained from DOJ, and a settlement was reached with SEC. Representation of an IT solutions provider in an investigation by the GSA Office of the Inspector General regarding potential False Claims Act violations stemming from compliance with price reduction clause requirements in a GSA Schedule contract. No enforcement action has been taken.

- Representation of a government contractor in an FCPA disclosure and subsequent cooperation with DOJ for a matter involving a commercial contract in a Middle Eastern country. A non-prosecution agreement was obtained with DOJ.

- Representation of a Fortune 500 defense industry company in a federal antitrust investigation involving alleged collusion between the company and one of its suppliers. The matter was closed without an enforcement action.

- Representation of a major defense industry company in a disclosure under the FAR mandatory disclosure rules and investigation by the DOJ Civil Division regarding potential violations of the Anti-Kickback Act by a procurement manager for the company. The matter was resolved without an enforcement action.

- Representation in an investigation by DOJ and DoD OIG of a government contractor regarding kickbacks received by a program manager for a program in a South Asian country.

- Representation of an individual in an investigation by DOJ of potential evasion of emissions regulations by a major European manufacturer.

- Internal investigation relating to potential improper payments and anti-competitive behavior in connection with a bid by the South American subsidiary of a major U.S. corporation in a government procurement process.

- Internal investigation relating to possible payments to a union official representing the blue-collar employees of the Mexican subsidiary of a major U.S. corporation.

- Counseling for a Fortune 50 company on all aspects of FCPA compliance, including discrete consultations on gifts and hospitality, third party due diligence, and employee training, as well as longer term advice on issues such as structuring joint venture relationships with adequate anti-corruption controls, augmentation and updating of ethics and compliance policies, review and legal analysis of internal investigations conducted internally or by other counsel for the company, and advice on the design of anti-corruption reviews of company subsidiaries.

Languages Spoken

Spanish

Portuguese

Education