William M. Sullivan, Jr. leads Pillsbury’s Washington, D.C. office Litigation practice and is the co-chair of the firm’s Corporate Investigations and White Collar Defense group. He concentrates on corporate internal investigations, trial practice and white-collar criminal defense, as well as complex civil litigation, securities enforcement, export control and other regulatory actions, with a particular emphasis on international criminal cartel enforcement and the Foreign Corrupt Practices Act. Before entering private practice, he served for more than a decade as an Assistant United States Attorney for the District of Columbia.
The new SEC disclosure requirements will put payments to foreign governments in the spotlight once again, so U.S. and foreign energy companies operating in countries with a high risk of corruption should expect an increase in FCPA investigations and, potentially, prosecutions. Be warned: the DOJ and the SEC will be on the lookout for evidence of FCPA violations.
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