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- Home
- Professionals
- Jennifer H. Saperstein
Jennifer H. Saperstein, vice chair of the Anti-Corruption Practice Group, advises clients on compliance issues arising under anti-corruption laws, including the Foreign Corrupt Practices Act (“FCPA”). An experienced compliance counselor, she frequently conducts risk assessments and compliance program assessments, and has developed anti-corruption compliance programs for clients across a wide range of industries. Ms. Saperstein also leads cross-cutting compliance projects to help companies build and improve their compliance programs across areas of regulatory expertise, bringing together teams of regulatory experts to provide integrated advice. Ms. Saperstein regularly assists companies with anti-corruption due diligence and compliance integration in connection with acquisitions, asset purchases, joint ventures, and other investment transactions.
Ms. Saperstein also helps corporations with efficient resolution of internal and government investigations into allegations of fraud and corruption.
Anti-Corruption and Cross-Disciplinary Compliance
- Advises multinational companies and associations in creating and implementing tailored anti-corruption policies and procedures.
- Performs anti-corruption risk assessments for companies and associations in a diverse range of industries, including life sciences, energy, consumer products, personal care, food and beverage, gaming, technology, manufacturing, transportation and logistics, and financial services.
- Advises multinational companies on building and enhancing compliance functions, implementing integrated compliance programs, and facilitating compliance monitoring through use of data analytics.
- Advises companies on third party integrity due diligence processes, designing criteria and procedures for diligence, assisting with selection of outside diligence vendors, and providing advice on specific vendors.
- Conducts targeted anti-corruption due diligence in connection with mergers, acquisitions, and investments
- Assists companies in complying with due diligence requests
- Provides customized anti-corruption training to legal, finance, internal audit, sales, and other departments.
- Provides ongoing counseling to dozens of clients on anti-corruption issues.
FCPA, Anti-Kickback Act, and False Claims Act Investigations
- Obtained declination from DOJ for a transportation and logistics company in an Anti-Kickback Act investigation by the DOJ.
- Conducted internal investigations for Fortune 50 companies, both in the U.S. and abroad, in connection with potential violations of the FCPA.
- Counsel to a major multinational company in a DOJ investigation into potential violation of the False Claims Act.
Pro Bono
- Representing plaintiff in challenge to agency rule-making.
- Represented plaintiff in § 1983 action against police and prosecutors in Jefferson Parish, Louisiana arising out of wrongful conviction and alleged Brady violations.
- Successfully represented defendant charged with multiple homicides in state court proceedings.
Rising Star: Covington's Jennifer Saperstein
August 7, 2020, Law360
Jennifer Saperstein has been named a Law360 Rising Star in Compliance.
July 21, 2020, Covington Alert
On July 17, 2020, Commonwealth Edison Company (“ComEd”), an Illinois utility company, entered into a deferred prosecution agreement (the “DPA”) with the U.S. Department of Justice (“DOJ” or the “Department”) to resolve allegations of bribery under 18 U.S.C. § 666, which prohibits theft or bribery concerning programs receiving federal funds. Aside from the ...
July 8, 2020, The Wall Street Journal
Jennifer Saperstein is quoted in The Wall Street Journal regarding the second edition of the guide to the U.S. Foreign Corrupt Practices Act. The guide warns companies that their internal accounting controls must take into account operational realities. Ms. Saperstein says the additional language appears to signal that the SEC will continue taking an expansive ...
July 6, 2020, Covington Alert
On July 3, 2020, the U.S. Department of Justice’s (“DOJ” or the “Department”) Criminal Division and the U.S. Securities and Exchange Commission’s (“SEC”) Enforcement Division quietly released A Resource Guide to the U.S. Foreign Corrupt Practices Act, Second Edition (the “Second Edition”). The first edition of the Resource Guide (the “First Edition”) was ...
July 6, 2020
WASHINGTON— Law360 has named Covington partners Sean Akins, Dustin Cho, Adrian Perry, Jennifer Saperstein, Kayleigh Scalzo, Ashley Simonsen, and William Woolston among its “Rising Stars.” Covington’s seven “Rising Stars” were the most of any firm this year. This annual recognition honors top lawyers under 40 “whose legal accomplishments transcend their age.” ...
June 3, 2020, Covington Alert
On June 1, 2020, the U.S. Department of Justice (“DOJ” or the “Department”) Criminal Division released an updated version of its Evaluation of Corporate Compliance Programs document (the “Guidance”), which serves as a reference for prosecutors in assessing corporate compliance programs in the context of DOJ investigations. The Department last revised the ...
April 27, 2020, Bloomberg Law
March 23, 2020
NEW YORK—The American Lawyer has named Covington lawyers Sergio Urías and Laura Torre as “Dealmakers of the Year.” The annual feature highlights “the most impressive and significant matters that deal lawyers worked on in 2019.” Shareholders of Covington’s client Prisma Medios de Pago, Argentina’s largest payment processing company, were mandated by the antitrust ...
January 30, 2020, Covington Alert
It has been another strong year in anti-corruption enforcement, with 2019 meeting or beating the high-water mark for enforcement across a number of measurements.
May 10, 2019, Covington Alert
On April 30, 2019, the U.S. Department of Justice (“DOJ”) Criminal Division released an updated version of the Evaluation of Corporate Compliance Programs (the “Guidance”), which serves as a reference for prosecutors in assessing corporate compliance programs in the context of DOJ investigations.
April 3, 2019, Covington Alert
In March 2019, the U.S. Department of Justice introduced several changes to the Foreign Corrupt Practices Act (“FCPA”) Corporate Enforcement Policy (“the Policy”). The Policy, originally incorporated into the Justice Manual in November 2017, outlines the Department’s position on mitigation credit that companies may receive for voluntary self-disclosure, full ...
April 3, 2019, Covington Alert
In March 2019, the U.S. Department of Justice introduced several changes to the Foreign Corrupt Practices Act (“FCPA”) Corporate Enforcement Policy (“the Policy”). The Policy, originally incorporated into the Justice Manual in November 2017, outlines the Department’s position on mitigation credit that companies may receive for voluntary self-disclosure, full ...
Q1 2019, Covington Alert
It was business as usual for FCPA enforcement in 2018. The U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) collected a total of $1 billion from seventeen corporate defendants, including through their share of two high-value, multi-jurisdictional enforcement actions. DOJ also announced thirteen new FCPA prosecutions ...
Winter 2019, Covington Alert
It was business as usual for FCPA enforcement in 2018. The U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) collected a total of $1 billion from seventeen corporate defendants, including through their share of two high-value, multi-jurisdictional enforcement actions. DOJ also announced thirteen new FCPA prosecutions ...
Covington Advises Argentinian Payments Company on Sale with Enterprise Value of $1.42B
January 22, 2019
NEW YORK—Covington advised Prisma Medios de Pago, Argentina’s leading payments company, in the sale of a controlling stake to Advent International. Prisma’s existing shareholders will retain a 49% stake in the company. The transaction values 100 percent of Prisma at $1.42 billion. Prisma is an Argentinian company established in 2014 through the merger of Visa ...
January 16, 2019, Covington Alert
On December 26, 2018, the U.S. Securities and Exchange Commission ("SEC") settled an enforcement action against Centrais Eléctricas Brasileiras S.A. ("Eletrobras"), an electric utilities holding company majority-owned and controlled by the Brazilian government.
September 28, 2018, Covington Advisory
On August 24, 2018, the Second Circuit issued its much-anticipated decision in U.S. v. Hoskins.Emphasizing on multiple occasions that Congress defined “with surgical precision” who could be liable under the anti-bribery provisions of the Foreign Corrupt Practices Act (“FCPA”), the court held that the government may not employ conspiracy or accomplice liability ...
April 30, 2018, Bloomberg Law
Jennifer Saperstein is quoted in a Bloomberg Law article regarding the Justice Department's decision not to press criminal charges against Dun & Bradstreet Co. because of the company's cooperation under the updated anti-bribery policy. According to Saperstein, Dun & Bradstreet’s approach demonstrated the full benefits the new system can offer, but the DOJ’s ...
January 25, 2018, Covington Advisory
Our message this year is simple: FCPA enforcement is here to stay. Despite pre-election statements to the contrary, various senior officials in the U.S. Department of Justice (“DOJ”) and U.S. Securities and Exchange Commission (“SEC”) have, over the past year, consistently reaffirmed DOJ’s and the SEC’s commitment to FCPA enforcement.
December 13, 2017, Covington Alert
During his keynote speech at the 34th International Conference on the Foreign Corrupt Practices Act (“FCPA”), U.S. Deputy Attorney General Rod J. Rosenstein announced a new FCPA Corporate Enforcement Policy (the “Policy”), which is now incorporated in the United States Attorneys’ Manual (“USAM”).
Compliance: How In-House and Outside Counsel Can Best Interact to Run an Internal Investigation
June 17, 2017, International Bar Association, World Life Sciences Conference
ISO 37001 Anti-Bribery Management Systems: Substance, Certification, and Open Questions
June 7, 2017, PLI Webcast
Fraud Section Guidance Highlights Factors Considered in Evaluating Corporate Compliance Programs
March 2, 2017, Covington Alert
The Fraud Section of the U.S. Department of Justice (“DOJ”) quietly released new guidance last month entitled “Evaluation of Corporate Compliance Programs” (the “Guidance”). While noting that “the Fraud Section does not use any rigid formula to assess the effectiveness of corporate compliance programs,” the eight-page Guidance outlines 11 “Sample Topics and ...
Winter 2017, Covington Alert
Anti-corruption enforcement is at a crossroads. In many respects, global anti-corruption enforcement has never been more active. The U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) in 2016 collected a total of $2.41 billion through FCPA enforcement actions against 27 corporate defendants, including through their share ...
Pre-Conference Workshop: Upgrading Your Third Party Due Diligence Process Post-Unaoil: How Much Due Diligence is Now Enough to Truly Vet Third Party Intermediaries
November 29, 2016, ACI’s 33rd International Conference on the Foreign Corrupt Practices Act
November 2, 2016, PLI’s Life Sciences 2016: Navigating Legal Challenges in the Drug and Device Industries
Covington Promotes 13 New Partners
October 3, 2016
WASHINGTON—Covington has promoted 13 lawyers to its partnership. “Our new partners reflect the excellence, strengths, and diversity of the firm and will play important roles in the firm for decades to come and will help drive our key practices to even greater success in the years ahead,” said Timothy Hester, Covington’s chair. The new partners, who are based in ...
October 3, 2016, Global Investigations Review
Global Investigations Review highlighted the promotion of Jennifer Saperstein and Aaron Lewis as partners of the firm. The article notes that Saperstein advises clients on Foreign Corrupt Practices Act matters and internal investigations while Lewis advises clients on white-collar defense and internal investigations, drawing on six years of Justice Department ...
Pre-Forum Working Group - Fundamentals of Anti-Corruption Compliance: Understanding the US Foreign Corrupt Practices Act
July 28, 2016, Panelist, ACI's FCPA Compliance & Enforcement Conference
Understanding the Complexities Surrounding Cross-Border Transactions with HCPs
March 17, 2016, Panelist, CBI's Global Anti-Corruption and FCPA Compliance Conference
Anti-corruption, FCPA, and Trade Controls: Current Developments
November 4, 2015, Panelist, PLI's Life Sciences 2015: Navigating Legal Challenges in the Drug and Device Industries
4/23/2012
NEW YORK, April 23, 2012 — Covington & Burling represented Thomson Reuters in a definitive agreement to sell its Healthcare business to an affiliate of Veritas Capital for $1.25 billion in cash. The sale, expected to close in the next few months, is subject to regulatory approval and customary closing conditions, including the expiration or termination of ...
5/16/2011
WASHINGTON, DC, May 16, 2011 — Joy Global Inc. (NASDAQ: JOYG), a worldwide leader in high-productivity mining solutions, reported today that it has signed a definitive agreement to acquire 100 percent ownership interest in LeTourneau Technologies, Inc. (“LeTourneau”) from Rowan Companies, Inc. (“Rowan”) (NYSE: RDC) for $1.1 billion in cash. LeTourneau designs, ...
2009, 24 Am. U. Int’l L. Rev. 843
- Law360, Compliance "Rising Star" (2020)

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Practices
Education
New York University School of Law, J.D., 2008
- magna cum laude
- Order of the Coif
- New York University Law Review, Articles Editor
Duke University, A.B., 2005
- summa cum laude
- Phi Beta Kappa