David W. Simon
Foley & Lardner LLP
United States

Partner David Simon heads the International Government Enforcement Defense & Investigations Team at Foley & Lardner. He provides compliance advice, conducts internal investigations, defends companies against enforcement actions, and represents companies in litigation. The Foreign Corrupt Practices Act (FCPA) and other anti-bribery laws are a principal focus of Mr. Simon’s practice: He has conducted investigations in, and has built active alliances with, law firms and attorneys in countries all over the world, from Asia to Europe to Latin America.

Representative Work:

• Led the team representing a publicly traded U.S. manufacturing company that discovered suspicious payments to an agent made by its Peru subsidiary. Helped the company navigate through the complex landscape this presented, including defending, and ultimately resolving, U.S. Department of Justice and U.S. Securities and Exchange Commission investigations with a civil settlement and criminal declination.
• Lead FCPA counsel for the Independent Compliance Monitor, engaged by a financial institution as mandated by its FCPA settlement agreements with the U.S. Department of Justice and U.S. Securities and Exchange Commission.
• Conducted an internal investigation to determine what had actually happened, and developed and helped the client implement a remediation plan to manage the risks associated with the conduct, when a U.S.-based, publicly traded manufacturing company received a compliance hotline report alleging that its India subsidiary had engaged a contractor that paid a bribe to facilitate permit approvals for its new factory.