Charles S. Leeper

Foreign Corrupt Practices Act

Charlie represents companies and individuals in Department of Justice (DOJ) and Securities and Exchange Commission (SEC) investigations of alleged FCPA violations, and he has successfully represented clients at trial when FCPA charges were filed. Charlie also helps clients identify FCPA risks and potential violations by conducting internal investigations, which he has handled in Asia, the Middle East and numerous other locales outside the U.S. In addition to defending against alleged FCPA violations, Charlie helps clients understand and comply with the FCPA. He designs due diligence protocols, training programs and ethical conduct codes.

Representative Experience

• Obtained dismissal of all FCPA and conspiracy charges on behalf of client following a four-month trial in United States v. Goncalves, et al. (D.D.C.)
• Represented U.S. contractor in a DOJ investigation of contracts performed in Iraq
• Conducted an internal investigation for a U.S. manufacturer in regard to distributor relationships in Serbia and Slovenia
• Conducted internal investigations for a U.S. manufacturer of alleged improper payments in Southeast Asia and Middle East
• Conducted an internal investigation for a U.S. beverage producer of invoicing and sales agent practices in Syria
• Represented insurance companies based in a U.S. Territory in a DOJ investigation of financial transactions in Nigeria

Antitrust

Charlie represents clients in antitrust investigations conducted by authorities in the U.S., Canada and the European Union. He defends domestic and international companies and individuals against allegations of bid-rigging, price-fixing, and market or customer allocation.

Representative Experience

• Represented companies at trial and successful appeal in which government alleged bid-rigging on construction projects financed by the U.S. Agency for International Development; United States v. Anderson, et al. (D.D.C.)
• Conducted an internal investigation for a drilling services company of suspected of bid-rigging and represented company it in a voluntary disclosure to competition authorities in Europe
• Secured declination of prosecution on behalf of an executive in an Antitrust Division price-fixing investigation of the helicopter transport services industry (N.D. Tex.)
• Secured declination of prosecution on behalf of the former CEO of a joint venture in an Antitrust Division price-fixing investigation of the elastomers industry (N.D. Cal.)
• Represented an airline executive in a DOJ investigation of pricing in the air cargo industry (D.D.C.)
• Obtained declination of prosecution for European sales executives in an investigation of alleged conspiracy to fix prices and allocate customers in the vitamins industry (N.D. Cal.)

Securities Fraud

Charlie represents companies, executives, attorneys and accountants in DOJ and SEC investigations of alleged securities violations, including financial statement fraud and insider training. He regularly persuades government enforcement authorities to decline prosecution of these alleged offenses.

Representative Experience

• A publicly traded reinsurer in connection with allegations of insider trading
• Partners and associates in a major law firm in connection with DOJ and SEC investigations of off-balance sheet entities used by Enron
• Sales and marketing executives in connection with parallel criminal and civil investigations arising out of alleged improper revenue recognition in the internet services industry
• The CFO of a major hedge fund in connection with DOJ and SEC investigations of alleged failure to disclose beneficial ownership of publicly traded securities.

Procurement Fraud

Government contractors and their executives rely on Charlie for representation at trial and in DOJ and Inspector General investigations of alleged False Claims Act and other procurement fraud violations. Charlie’s prior law enforcement experience enables him to prepare effective defenses to these alleged violations, many of which require investigation of events in conflict zones and other hostile locales.

Representative Experience

• Represented a non-U.S. contractor in a DOJ investigation of alleged kickbacks on contracts awarded by the U.S. Department of Defense for reconstruction work in Iraq
• Obtained declination of prosecution for computer manufacturers in DOJ investigations of procurements by the FBI and the DEA
• Obtained declination of prosecution for prime contractor on construction of federal courthouses in New York and Nevada in connection with investigation of alleged bribes and kickbacks

Government Experience

As an Assistant U.S. Attorney, Charlie investigated and prosecuted white collar, public corruption, espionage and terrorism cases. He also supervised a team of veteran prosecutors in his capacity as Deputy Chief of the Special Prosecutions Unit.

Personal Interests

Charlie is an avid fly fisherman and even more avid grandfather.