Audrey has led numerous cross-border investigations focused on anti-bribery laws, for example the US Foreign Corrupt Practices Act and the UK Bribery Act (UKBA), sanctions, financial fraud and revenue recognition in countries like Russia, China, France, Switzerland, Finland, Malawi, Mozambique, Somalia, South Africa, Iraq, Saudi Arabia, UAE, Australia, the UK and US.
She represents clients in US, UK and multinational regulatory investigations, including those brought by the US Department of Justice, the US Office of Foreign Assets Control (OFAC), the US Commodity Futures Trading Commission, the US Federal Reserve, the UK Serious Fraud Office (SFO), the UK Competition and Markets Authority and various other international regulators.
Audrey regularly advises clients on anti-bribery, anti-corruption, sanctions and corporate governance compliance, due diligence and related training. Her experience includes reviews of corporate compliance provisions, procedures and structures, conducting regulatory risk assessments, and providing advice on their enhancements, including implementing compliance programmes.
Audrey has represented clients across sectors including financial services, life sciences & pharmaceuticals, energy, natural resources & chemicals, private equity, real estate, construction, engineering, manufacturing, technology, media & telecommunications.
Audrey spent 16 months seconded to the SFO as an investigative lawyer in the Bribery & Corruption Division. She focused on the prosecution (including negotiation of Deferred Prosecution Agreements) of complex, multi-jurisdictional bribery and corruption cases under the UKBA and its preceding legislation, and successfully defended judicial review proceedings.
Examples of experience include advising:
- Two major French banks in OFAC sanctions investigations before six and five US government agencies respectively
- A leading Euronext-listed construction company with operations in Africa in an internal investigation regarding alleged corruption, and the design and implementation of an enhanced anti-corruption compliance programme, including internal controls enhancements and training
- A multinational healthcare corporation in various internal investigations involving corruption issues in the Middle East and a medical device US issuer in various investigations in China and Australia relating to grants, improper payments to doctors and kickbacks from distributors
- An American conglomerate focused on the natural resources & chemicals, media & telecommunications and real estate industries, on dawn raids, anti-bribery, anti-corruption, sanctions and corporate governance compliance, due diligence, IT security and related training
- A diversified multinational mass media and entertainment conglomerate and a Fortune 500 healthcare services company on compliance due diligence and negotiating compliance representations in their Russian and US M&A transactions
- A private equity fund manager in the oil & gas sector with regards to their ongoing regulatory risk assessments of their portfolio investment companies, compliance due diligence and negotiation of compliance representations in their European M&A transactions.