Complying with the Foreign Corrupt Practices Act

Kimberly A. Parker is a partner in WilmerHale’s Washington office. Ms. Parker co-leads the firm’s Foreign Corrupt Practices Act and Anti-Corruption Practice. Ms. Parker has represented companies and individuals in numerous FCPA enforcement matters. She has conducted FCPA internal investigations in the United States, Asia, Africa, Europe, and Latin America and she regularly provides FCPA compliance and governance advice. Ms. Parker has co-authored Complying with the Foreign Corrupt Practices Act since 2005, is a regular speaker at leading FCPA conferences, and has published numerous articles on the FCPA. Ms. Parker has been selected as national FCPA leader in Chambers Leading Lawyers for Business and has been recognized among the top Women in Investigations by Global Investigations Review.

Jay Holtmeier is a partner in WilmerHale’s New York office. Mr. Holtmeier’s breadth of experience as a litigator includes service as a federal prosecutor, a senior in-house attorney, and a lawyer in private practice. Mr. Holtmeier represents institutions and individuals in complex government and internal investigations and matters of corporate governance and compliance, and he co-leads the firm’s FCPA and Anti-Corruption Practice. In FCPA matters, Mr. Holtmeier has conducted investigations involving conduct in Europe, Asia, the Middle East, Africa, Latin America, Canada, and Australia, including several that have been subject to resolutions with government enforcement authorities. He regularly counsels clients facing difficult FCPA issues in a variety of business contexts, and he has assisted clients in numerous industries in developing and implementing FCPA compliance programs. He devotes substantial attention to advising clients on FCPA problems that arise in the context of mergers and acquisitions, joint ventures and other corporate transactions. Mr. Holtmeier has co-authored Complying with the Foreign Corrupt Practices Act since 2010 and regularly writes and speaks on FCPA issues. He regularly is ranked among top white collar and FCPA practitioners in Chambers and Best Lawyers in America.

Erin G.H. Sloane is a partner in WilmerHale’s New York office, and is a member of the firm’s Investigations and Criminal Litigation Practice Group. Ms. Sloane’s practice focuses on government and internal investigations and white collar criminal matters, with a concentration on Foreign Corrupt Practices Act and international anti-corruption issues. She represents both institutions and individuals in government investigations and FCPA enforcement matters, and has conducted multiple complex investigations in Europe, Russia, China, the Middle East, and Latin America Ms. Sloane also regularly counsels clients on challenging FCPA 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. She frequently speaks and writes on anti-corruption issues and has co-authored Complying with the Foreign Corrupt Practices Act since 2016. In 2019, Ms. Sloane was appointed as an independent compliance monitor by the Department of Justice (DOJ) and Securities Exchange Commission (SEC) in connection with the FCPA resolution of a major multinational health care company.

Christopher Cestaro is a partner in WilmerHale’s Washington office in the White Collar Defense and Investigations Practice. Mr. Cestaro’s practice focuses on white-collar criminal matters, government enforcement actions, internal corporate investigations, due diligence reviews and compliance counseling. Mr. Cestaro served as the Chief of the Foreign Corrupt Practices Act (FCPA) Unit of the US Department of Justice (DOJ). As the Chief of the FCPA Unit from 2019 to 2021, Mr. Cestaro was responsible for supervising all criminal FCPA investigations, prosecutions and resolutions in the United States. As the head of the FCPA Unit, Mr. Cestaro played a lead role in establishing and implementing the government’s FCPA enforcement strategy and Mr. Cestaro was involved in formulating DOJ policy and practice regarding FCPA and corporate enforcement.

Emily Stark is of counsel in Wilmer Hale's Washington office. Ms. Stark has significant experience representing companies in government and internal corporate investigations. She has substantial experience in matters involving the FCPA, anti-corruption compliance and risk assessments, as well as experience representing clients in anti-corruption investigations conducted by the World Bank. Ms. Stark also frequently advises clients on the strength of their compliance programs and enhancements needed to mitigate risk. She counsels clients across a range of industries and geographies in regard to enhancing and updating anti-corruption policies and procedures, ensuring robust internal controls, and anti-corruption compliance training.