INDIA INVESTIGATIONS
Practice Areas · Disputes, Recovery & Defense

FCPA & Anti-Corruption

Voluntary disclosure, root-cause investigation and remediation of corruption risk in India, coordinated across US enforcement and Indian law.

What this covers

Corruption exposure in India usually surfaces through a whistleblower complaint, an audit finding, something found during integration, or a referral from a regulator. The response then has to work under US and Indian law at the same time. I support it from the first indication through disclosure and remediation.

Under the Department of Justice’s Corporate Enforcement and Voluntary Self-Disclosure Policy, which since March 2026 applies to all corporate criminal matters, a company that voluntarily discloses, cooperates and remediates can receive a declination unless there are aggravating circumstances. Remediation that is done early and documented properly is part of that record. Because I am admitted in both the US and India, I can run the US disclosure strategy and the Indian legal steps together.

An engagement can cover:

An engagement starts with what has surfaced, where the exposure sits, and the timeline the matter is on. If something has surfaced in India, do reach out and I will take a look.

Representative matters in this area

01

An anti-corruption review before the regulator asked

The India arm of a US technology company worked through resellers and subcontractors, some of them dealing with government customers. Nothing had gone wrong, and the parent wanted the exposure examined while the review was still voluntary. The review covered the compliance framework, dealings with government, interviews and transaction sampling, and ended in a remediation report.
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02

Building a compliance program from zero

A US group's India venture needed an anti-corruption program built. The work scored the risks against actual exposure, mapped each risk to a control, drafted policies meant to be followed, trained the people who would apply them, and set out a sequenced rollout.
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03

FCPA diligence through US counsel

A US law firm, advising on a transaction with corruption exposure, instructed FCPA due diligence on the target, covering its ownership, history, dealings with government and the people behind it. The work was instructed through counsel from the start, so the findings could be protected as work product.
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Identifying details in these accounts have been changed so that no client, subject or matter can be identified.
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