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Compliance and Investigations

Compliance and Investigations

Key Contacts

Cambodia

Laos

Myanmar

Thailand

Vietnam

OVERVIEW

Working with you to prevent corruption and economic crime in Southeast Asia.

Tilleke & Gibbins’ offices are based in Southeast Asian countries that are attractive destinations for foreign investment. These countries, however, can also be high-risk environments for corruption, fraud, and other forms of economic crime. Local governments have been increasing their own anti-corruption and regulatory investigation efforts, changing the compliance and enforcement landscape. Failing to curb or prevent corrupt acts, economic crimes, or regulatory breaches can have devastating business, legal, and reputational consequences.

Tilleke & Gibbins offers a wide array of specialist legal, regulatory, and practical advice on government and internal investigations, white-collar defense, compliance, and anti-corruption matters, tailored for local jurisdictions. Our multi-jurisdictional team can assist you seamlessly across borders with a deep knowledge of local business practices and cultures.

Our investigation and compliance practice includes:

  • Internal corporate investigations
  • Advising clients on criminal and regulatory investigations
  • Advising clients on the Foreign Corrupt Practices Act and the U.K. Bribery Act
  • Providing insight into local anti-corruption laws, regulatory regimes, and business culture
  • Designing, advising, and implementing compliance programs
  • Anti-corruption due diligence on agents, partners, and M&A targets
  • Anti-corruption risk assessments and audits
Case Studies

Experience

  • Advised a leading multinational pharmaceutical company on conducting an anti-corruption compliance audit in its Thai subsidiary. Prior to the audit we provided advice to the client and its U.S.-based global anti-corruption counsel on Thai anti-corruption law and compliance issues in the Thai healthcare industry. After the audit, we reviewed relevant interview notes to identify potential red flags and areas for compliance enhancement.
  • Representing a world-leading manufacturer in a USD 200+ million global fraud case involving former employees in the company’s Thai operations. Among other things, we conducted employee investigations and interviews, advised on termination of employees, and liaised with the Crime Suppression Division of the Royal Thai Police, various embassies, the Anti-money Laundering Office, and similar offices in other jurisdictions around the world.
  • Prepared anti-corruption, anti-money laundering, and unfair competition compliance policies for a multinational corporation with operations in over 100 countries, including countries with extraterritorial anti-corruption laws such as the FCPA. We also advised on the implementation of our client’s compliance program in Thailand, which involved tailoring our client’s global compliance concerns to the local Thai jurisdiction.
  • Worked with a leading multinational law firm, and acted as local counsel on an internal corporate anti-corruption investigation at the Thai subsidiary of a global beverage manufacturer. We assisted the client in interviewing employees to gather crucial information, reviewed evidence, and advised on various issues of Thai law, including anti-corruption, tax matters, property, and regulatory licenses, among others, to help the client identify if alleged bribes actually took place.
  • Assisted an industry-leading provider of computer storage technologies and solutions, with an internal investigation and review of claimed wrongdoing by a senior-level Thai administrative employee. We conducted a thorough review of preliminary investigative reports to assist in our conduct of on-the-ground employee interviews and assessments, and provided detailed summaries and reporting of our investigative findings and advice on Thai law.
  • Acted for the Thai subsidiary of a multinational plate glass manufacturer in a high-stakes criminal investigation by Thailand’s Department of Special Investigation (DSI) for allegedly purchasing black market minerals for use by its manufacturing facility.
  • Assisted a multinational project management company in conducting an internal investigation involving bid rigging on energy and infrastructure projects in Thailand and across Southeast Asia. Our investigations uncovered significant wrongdoing by an employee, which motivated the client to revamp their internal policies to avoid similar situations in the future.
  • Advised several pharmaceutical companies on anti-corruption regulations related to their business dealings and procurement contracts with Thai government hospitals.
  • Advised a global food and beverage company on an extensive internal anti-corruption investigation in Thailand.
  • Assisted a multinational energy services company on an internal bid-rigging investigation in Thailand.
  • Advised a European pharmaceutical company on an internal fraud and anti-corruption investigation in Vietnam.
  • Assisted a global energy services firm on defending an anti-corruption investigation brought by the Thai authorities.
  • Designed and implemented a compliance, ethics, and health care professional dealings program across a client’s Southeast Asia offices.

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