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Ben Haley leads the firm's White Collar and Anti-Corruption Practice in Africa and is a vice chair of the firm's broader Africa Practice. With deep experience representing clients before U.S. regulators in high-profile matters and a history operating on the ground across the continent, he helps clients assess and mitigate complex legal and compliance risks in Africa.

Clients often call upon Mr. Haley to assist in the resolution of complex government enforcement matters and commercial disputes. For more than a decade, Mr. Haley has handled complex government enforcement matters and internal investigations, with particular expertise in anti-corruption, anti-money laundering, fraud, and financial crime matters. He has guided clients across a range of industries to favorable outcomes in government investigations, as well as parallel shareholder litigation, insurance recovery matters, and employment disputes.

Government Enforcement Matters

  • Counsel to Mobile Telesystems PJSC in resolution of DOJ and SEC FCPA investigation into the company’s former operations in Uzbekistan. 
  • Counsel to Anheuser-Busch InBev in securing a complete declination in 2016 from DOJ and a favorable settlement from the SEC in connection with parallel FCPA investigations of former joint venture in India.
  • Counsel to leading media and education organization in FCPA investigation into activities in North Africa, resulting in declination of prosecution by DOJ.  
  • Led representation of Fortune 100 manufacturing company in a 17-month FCPA investigation by the SEC and DOJ that concluded without enforcement action. 
  • Successfully resolved a long-running DOJ and SEC investigation involving alleged FCPA violations in Eastern Europe and Latin America by a leading global technology company.
  • Representation of a financial services client in an FCPA investigation relating to hiring practices, resulting in declination of prosecution by DOJ.
  • Conducted and reported to SEC on investigations in Nigeria, Uganda, Ghana, China, Argentina, Peru, and Brazil for client under post-resolution reporting obligation, resulting in no enforcement action. 
  • Representation of technology company in wide-ranging DOJ investigation into corporate communications and security practices, including forensic review of potential data destruction. 
  • Representation of technology company in U.S. Office of Foreign Asset Control investigation into potential trade controls and sanctions violations arising out of shipment of goods to Iran.  
  • Representation of an executive of an automotive manufacturer in a DOJ and SEC investigation into alleged FCPA violations in Eastern Europe.
  • In a matter that concluded without enforcement action, representation of a large regional bank in an SEC inquiry concerning mortgage loan repurchase reserves.
  • Representation of a pharmaceutical executive in an SEC and DOJ investigation relating to alleged disclosure, accounting, insider trading, and other securities law violations, resulting in a favorable SEC resolution and declination by DOJ.
  • Representation of a consulting firm audit committee member in an SEC investigation into accounting irregularities.
  • Representation of bank employee in False Claims Act investigation relating to bank’s quality control processes for compliance with federal loan programs, resulting in no enforcement action against our client. 

Internal Investigations

  • Internal investigation in Nigeria into potential FCPA, UK Bribery Act, and AML issues relating to tax obligations, licenses and permits, and immigration processes. 
  • Internal investigation in Ghana relating to immigration matters. 
  • Internal investigation in Uganda relating to interactions with police. 
  • Internal investigation into potential FCPA violations for manufacturing company relating to import of goods in Argentina and Brazil.
  • Internal investigation for oil and gas services company into potential FCPA issues arising out of transactions in Eastern Europe. 
  • Internal investigation for manufacturing company relating to potential FCPA concerns relating to public sector transaction in Georgia. 
  • Led team in fast-moving internal investigation into workplace violence incident involving major public sector technology contractor. 
  • Counsel to the Special Litigation Committee of the Board of Directors of Hewlett-Packard Company in shareholder derivative litigation relating to the Board's response to leaks of confidential company information.
  • Counsel to the Special Litigation Committee of the Board of Directors of InfoGROUP in connection with shareholder derivative litigation focusing on self-dealing and misuse of corporate assets.
  • Counsel to the Audit Committee of a publicly traded real estate investment trust in an investigation relating to debt covenant compliance and financial reporting issues. 
  • Investigations for Korean consumer products company relating to interactions with tax officials, expense fraud, and relationships with labor unions. 

Compliance Advisory Matters

  • Lead compliance counsel in one of the largest M&A transactions in the last decade, acting for a Fortune 200 consumer goods company, including leading pre-acquisition and diligence and post-acquisition integration efforts on the ground in Africa, India, Europe, and Latin America.
  • Representing major financial institution in East Africa on sanctions and AML matters.
  • Post-resolution review of anti-corruption compliance program for U.S. publicly listed company, including two reports to SEC on status of company's compliance program.  
  • Lead compliance counsel on joint-venture transaction for consumer goods company in Russia, including expedited post-acquisition compliance review. 
  • Lead counsel in accelerated post-acquisition financial controls enhancement project in Nigeria. 
  • Assisting company in development of control framework and third-party diligence and oversight processes for construction of major industrial facility in Nigeria.
  • Advice to oil exploration and production company on third-party relationships in Ghana.
  • Market entry advice to oil exploration and production company in Senegal, Mauritania, and Ghana.
  • Development of control processes and protocols for interactions with police and customs officials in various countries in Africa. 
  • Advice to U.S. publicly listed company regarding minority investments in Angola, Zimbabwe, and South Africa.
  • Advice to U.S. publicly listed company regarding currency repatriation and shareholder loans in Angola.
  • Anti-corruption, sanctions, and AML compliance advice relating to extortion payments in Central America.     
  • Global anti-corruption risk assessment for global manufacturing and technology company, including site visits in Mexico, Colombia, Venezuela, Argentina, Brazil, China, India, and South Africa.
  • Assisting Korean company with accelerated anti-corruption program enhancement project, including development of implementation roadmap. 

Dispute Resolution 

  • Representation of insurance policyholders on a variety of directors-and-officers and professional liability matters, including shareholder, insolvency, trade secret, and franchise litigation. 
  • Represented S&P Global on insurance coverage matters relating to litigation arising out of credit ratings issued in the mid-2000's.
  • Representation of energy company in two successful jury trials over coverage for environmental liabilities.
  • Representation of Thomson Reuters in patent litigation, obtaining the reversal of an $85 million jury verdict.   

Pro Bono

  • § 1983 action against Orleans Parish District Attorney and City of New Orleans and members of its police department on behalf of a plaintiff who was wrongfully convicted and sentenced to over 34 years in prison.
  • § 1983 action against the city of Covington, Louisiana and members of its police department on behalf of a plaintiff who was wrongfully convicted and exonerated by DNA evidence; obtained over $2 million in total recovery in settlement of this action and related state court litigation.
  • § 1983 action against police and prosecutors in Washington Parish, Louisiana arising out of wrongful conviction of Brady violations.
  • § 1983 action against police and prosecutors in Jefferson Parish, Louisiana involving allegations of Brady violations.
  • Represented an indigent defendant in Maryland on felony handgun charges. Obtained a favorable plea agreement with no jail time where defendant faced mandatory minimum.
  • Legal Media Group's Expert Guide, White Collar Crime Rising Star (2017)
  • Washington DC Super Lawyers, Criminal Defense: White Collar "Rising Star" (2014-2015)
  • Charles F.C. Ruff Pro Bono Lawyer of the Year (2014)
  • Part of Covington team named Outstanding Volunteer Counsel by Innocence Project, New Orleans for representation of wrongfully convicted clients in Louisiana