Associate General Counsel
Current•Devised distributor compliance program for business division including: creating (with outside counsel) risk matrix to account for third-party country of domicile, assigned territory, revenue, and sales channels; drafting due diligence questionnaire for use in onboarding as well as ongoing, periodic diligence; created diligence schedule for use in conjunction with contractual audit rights; and coordinating with business team to rollout compliance program for maximum adoption by third-parties.•Drafted and negotiated distributor agreements for business division for use in the United States and globally incorporating representations, warranties and covenants addressing trade compliance, anti-corruption compliance, audit rights, marketing obligations and restrictions, data privacy, and labeling compliance.•Developed (with outside counsel) antitrust law-compliant minimum advertised pricing policy for business unit. Drafted: unilateral minimum advertised pricing policy, all approved communications between the company and third-parties, communications procedure to direct company personnel on communications with third-parties regarding the policy, and investigations procedure for determining and responding to violations of the policy. Coordinated with the business team and outside counsel on appropriate penalties for violations of the policy.•Developed procedure for processing dynamic screening reports from vendor specializing in trade sanctions data. Co-developed (with enterprise applications team) WebApp for use in documenting research into denied parties, upstream and downstream business partners, as well as end user customer to determine if any are listed on the various sanctions lists promulgated by the US, UK, EU, and Australian governments. Drafted procedure document for inclusion in larger global corporate compliance program.
