My practice focuses on corporate compliance program issues, with a particular expertise in anti-corruption compliance programming. I am experienced in white collar matters, internal investigations, and risk mitigation, particularly those related to the Foreign Corrupt Practices Act (FCPA).

Perform a leadership role in the Global Compliance program and direct the program in Avon’s most valuable region.
Liaise cross-functionally to implement the U.S. Department of Justice and Securities and Exchange Commission ForeignCorrupt Practices Act (FCPA) settlements, including facilitating the independent monitor’s work and recommendations.Utilize risk assessment metrics to identify focus areas and drive business integrity solutions efficiently and effectively.Partner with Corporate and Regional leadership to ensure Compliance is embedded consistently and sustainably.
Provide subject matter expertise and legal counsel in the designing, drafting, implementation and interpretation ofCompliance policies and procedures with a focus on key anti-corruption-related legal and accounting controls.Create and execute risk-based processes for third parties, gifts, entertainment, contributions and training.Design and implement best practices through policies, communications, training, governance and special projects.Play a leadership role in cross-functional internal monitoring and auditing exercises to detect and remediate risks.
Develop incentive and discipline programs to foster a culture of integrity for both new and existing employees.Supervise a team of in-market and headquarters-based Compliance professionals to ensure consistent program execution.Conduct investigations into allegations of violations of law or corporate policy and participate in remediation processes.

Play a leadership role in the execution of the Global compliance program generally, including enhancing the compliance program by providing subject matter expertise in legal analysis, guidance, counseling and advice and input in the design of global policies and procedures, communication strategies, employee training and key compliance-related controls. Help lead program efforts to adopt consistent contract language and monitoring processes to facilitate employee and third party agent compliance with the policies and procedures required, particularly for U.S. Federal regulatory risks. Participate in planning and conducting cross-functional risk assessments designed to detect and address compliance risks.Counsel on compliance-related questions, implementation and execution of Global anti-corruption and other policies, as well as assist with the design and implementation of compliance remediation programs as necessary. Keeps abreast of and maintain a database with respect to statutory, legislative and regulatory developments in U.S. Federal regulatory risk areas as well as relevant jurisdictions, and communicate developments throughout the Legal Department and the business units, as appropriate.Periodically review and update Company policies to ensure continuing currency and relevance in providing guidance to management and employees. Upstream market data and experience to Global for sharing of best practices on a worldwide basis, as well as draft implementation guidelines based on experience in the markets. Working with Legal Department colleagues, especially colleagues from Global Ethics & Compliance, collaborate with other departments (Human Resources, Finance, etc) to develop an effective compliance training program and play a key role in the roll-out of such program. Advise on periodic monitoring and evaluation programs to effectively assess compliance of processes that are in place.

I focused my practice on white collar criminal and quasi-criminal defense with a particular emphasis on the Foreign Corrupt Practices Act (FCPA) and Office of Foreign Assets Control (OFAC) regulations. I represented a range of corporate clients from privately held entities to Fortune 10 corporations in a variety of FCPA and OFAC matters, including internal investigations, transactional due diligence, preparing compliance policies and procedures, conducting compliance audits and leading compliance training exercises. I also represented companies and individuals in a variety of white collar criminal and civil internal investigations and litigation matters.

I was a summer associate at the Inter‑American Development Bank in Washington DC, where I provided counsel concerning to the bank’s financial and investment policies and interpreting the bank’s immunities and privileges in its 47 member countries.