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Anti-Corruption Investigations & Compliance

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  • Key Contacts
  • Select Experience
  • Recent Recognition
  • Insights, News & Events
  • Related Services
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  • Recent Recognition
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Companies engaged in cross-border trade, investment, or projects reliant on government approvals can face acute corruption risk. Multi-jurisdictional investigations and heightened compliance expectations require experienced counsel to help guide companies to do business cleanly, and to address and remediate concerns when they arise. Bennett Jones' Anti-Corruption Investigations and Compliance team offers multi-disciplinary and skilled counsel to companies navigating corruption risk and business ethics exposure.

The Corruption of Foreign Public Officials Act (CFPOA) and provisions of the Criminal Code place strict duties on Canadian companies and their employees and agents not to engage in corrupt behaviour. The CFPOA, the Canadian equivalent to the United States Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, criminalizes payments of any kind and in any form to foreign public officials for the purpose of seeking to gain any business advantage. Domestic bribery offences prohibit a variety of conduct, including breaches of trust and the acceptance or offer of secret commissions. Companies face heightened risk disclosure scrutiny from securities regulatory authorities, as in recent years, Canadian securities regulators have used existing regulatory mechanisms to address corruption and related concerns.

In addition, more recent regulatory and transparency initiatives, including those related to Canada's Integrity Regime for federal procurement, and the Extractive Sector Transparency Measures Act (ESTMA), create additional business ethics and reporting obligations. Companies that fall under these regimes must navigate reporting and compliance challenges, which present the associated existential risks of losing the ability to bid on government contracts or facing quasi-criminal enforcement action.

We assist clients with the following:

  1. Government and Regulatory Investigations;
  2. Compliance, and Internal Audits & Reviews; and
  3. Mergers & Acquisitions.

Government and Regulatory Investigations

Governments worldwide are increasingly focusing on anti-corruption compliance, including pursuing criminal prosecution under relevant legislation and cooperating and sharing information among enforcement authorities in other jurisdictions. Bennett Jones lawyers have extensive experience advising clients facing government and regulatory investigations. We work closely with our counterparts in the United States and Europe on suspected cross-border corruption matters, often involving the United States Securities and Exchange Commission, the US Department of Justice, the UK Serious Fraud Office, and other foreign criminal and regulatory authorities. At home, we have represented clients in numerous confidential corruption matters resolved without charges before Canadian law enforcement (Royal Canadian Mounted Police, Public Prosecution Service of Canada), in matters involving corruption risk disclosure before securities regulators (Ontario Securities Commission), and in debarment proceedings conducted by public procurement authorities (Public Services and Procurement Canada).

Compliance and Internal Audits and Reviews

We provide practical and targeted advice to help companies identify and mitigate the corruption risks they face when doing business in Canada or abroad. Our team has assisted companies to establish and strengthen anti-corruption compliance programs across industry sectors, including in the Natural Resources (Mining and Oil & Gas), Manufacturing, Engineering, Technology, Aerospace, and Cannabis sectors. In designing anti-corruption compliance programs and strategies, we also leverage our expertise in related areas such as export controls and sanctions, public procurement, and trade compliance. Our team is regularly engaged to conduct internal audits and company-initiated reviews in relation to potential misconduct, including matters that arise through whistleblower reports, internal controls, or due diligence processes.

Mergers & Acquisitions

We conduct M&A due diligence reviews, and provide compliance, regulatory, business ethics, and governance advice to boards of both public and private companies, acting for both potential acquirers and putative targets as they consider their merger, acquisition, and amalgamation options.

Our lawyers write, teach and speak regularly on the topics of anti-corruption and bribery compliance, and the conduct of investigations.

Read more about the full spectrum of services offered by our International Trade and Investment group.

Key Contacts

  • Sabrina A. Bandali Sabrina A. Bandali, Partner
  • ,
  • George W. H. Reid George W. H. Reid, Partner
  • Related Lawyers

Select Experience

A global health science company, with an RCMP investigation into alleged improper payments to Russian officials
A precious metals mining corporation, in an investigation of shareholder allegations of improper payments to public officials in South America
An engineering and manufacturing company in the oil & gas industry, in relation to an investigation of employee allegations of corrupt payments made to Chinese officials
An aerospace industry company, with respect to agent and counter-party anti-corruption compliance matters
A Latin American oil & gas company, in relation to an M&A compliance review
A global mining company, in relation to a risk-disclosure review by, and settlement with, the Ontario Securities Commission
A global manufacturer of construction and mining equipment, in relation to allegations of improper payments made to public officials in connection with infrastructure bids in multiple foreign jurisdictions
A global apparel manufacturer, with an internal investigation of questionable payments made in relation to manufacturing activities in South Asia
A publicly-traded Canadian mining and metals company, in relation to due diligence for corporate social responsibility and community support payments for a project in Africa
A publicly-traded Canadian energy company, to develop a corruption risk mitigation strategy in relation to a politically sensitive investment in a foreign jurisdiction
A Canadian resident executive, in relation to a DOJ/SEC investigation of the executive's company
A Canadian oilfield services company, investigating a commercial intermediary tied to an ongoing corruption investigation in South America
A global, publicly-traded conglomerate, regarding potential improper payments in a public procurement
A global, publicly-traded manufacturer, in connection public procurement debarment proceedings

Recent Recognition

Chambers Canada
Band 1, White-Collar Crime & Government Investigations
Band 1, Litigation: Securities - Ontario
Ranked, International Trade/WTO
Chambers Global
Band 1, International Trade/WTO
Global Investigations Review: GIR 100
Ranked as a leading firm globally in Investigations
The Legal 500: Canada
Ranked, International Expertise
Ranked, International Trade

Insights, News & Events

Announcements

Bennett Jones Top Ranked in Chambers Canada 2025

September 26, 2024
       
2024
May
01
       

Event

Securing Integrity: Internal Investigations of Securities-Related Wrongdoing

Calgary

Speaking Engagements

Cross-Border Civil Fraud Recovery & Injunctive Relief and Cross-Border Private Investigations

April 18, 2024
       

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International Trade & Investment
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