Attorneys At Law
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Iris E. Bennett

Member

Tysons Corner Office
8000 Towers Crescent Drive, Suite 900
Tysons Corner, VA 22182
Phone: (703) 839-8120
Fax: (703) 847-6312

Ms. Bennett has deep experience counseling clients on the investigation, defense, and resolution of white collar matters, as well as the corporate compliance programs designed to avoid such liabilities.  She has represented numerous Fortune 100 corporate and individual clients in matters relating to potential violations of criminal or civil fraud statutes, including the Foreign Corrupt Practices Act (FCPA), the False Claims Act, the Anti-Kickback Act, and antitrust laws.   She has also represented companies in matters implicating the federal mandatory and voluntary disclosure rules and brought those matters to successful resolution.  She has conducted internal investigations in cases across the globe and represented companies before the Criminal and Civil Divisions of the Department of Justice as well as the Securities and Exchange Commission, in all phases of U.S. government investigations and settlement.  Ms. Bennett’s fluency in Spanish has enabled her to conduct many investigations in that language.  In addition to her extensive investigation and defense experience, Ms. Bennett has years of FCPA compliance counseling experience.  She regularly advises corporate clients on their anti-corruption compliance programs and on specific policies, procedures and compliance questions.  She has also designed and led large-scale corporate compliance reviews and audits. 

Ms. Bennett clerked for the Honorable Robert W. Sweet of the United States District Court for the Southern District of New York, and for the Honorable David S. Tatel of the United States Court of Appeals for the District of Columbia.  Ms. Bennett entered private practice after serving as a federal criminal defense lawyer in the District of Columbia Federal Public Defenders’ office.

Education

New York University School of Law, J.D., 1999; magna cum laude; Order of the Coif; New York University Law Review
Harvard College, A.B., 1989; summa cum laude; Phi Beta Kappa

Bar Admissions

State of California, 2000

District of Columbia, 2005

Commonwealth of Virginia, 2016

Court Admissions

U.S. Supreme Court, 2009
U.S. Court of Appeals, Seventh Circuit, 2008
U.S. Court of Appeals, District of Columbia Circuit, 2002
California State Courts (all), 2000

Publications

Author, Practicing Under the U.S. Anti-Corruption Laws, Aspen Book Publishers, 2013 Edition, May 2013

"Foreign Corrupt Practices Act: Central District of California Rejects Argument that State-Owned Corporations Can Never Be 'Instrumentalities' of Foreign Governments," Business Law Today, June 16, 2011

“Sharing is Caring in DOJ’s View of FCPA Cooperation,” Law360, December 7, 2010

"Honest Services after Skilling: Judicial, Prosecutorial, and Legislative Responses," Criminal Litigation, Vol. 11, No. 1, American Bar Association Section of Litigation, Fall 2010

"FCPA Prosecutions: Lessons Learned from U.S. v. Green," Bloomberg Law Reports: Risk & Compliance, February 16, 2010

"Signs of Life in International Anti-bribery Enforcement - Recent Enforcement of Anti-bribery Laws Outside the U.S. and Issues to Consider for a Multi-jurisdictional Defense Strategy," Bloomberg Law Reports: Corporate Law, May 4, 2009

"Recent 9th Circuit Case May Impact Litigation Risk in Mergers," Law.com, January 22, 2009

"No Cash Required: The Foreign Corrupt Practices Act and Corporate Risk," Ethisphere, Quarter 3, 2008

"Corruption Remains a Business Risk," The National Law Journal, March 31, 2008

Speaking Engagements

Speaker: With co-panelists Rochelle (“Shelly”) Cooper, Senior Vice President, General Counsel and Corporate Secretary for IAP Worldwide Services, Inc., and Maria E. Gomez, Regional Compliance Officer for Latin America for General Motors Corporation, led a workshop and panel discussion on the Foreign Corrupt Practices Act at the 2016 Women, Influence & Power in Law conference, held in Washington, D.C.  The WIPL annual conference brings together women corporate counsel, outside counsel, and public sector attorneys who are in leadership positions at their companies, firms, and agencies, to discuss critical legal issues in corporate law and compliance, and to provide a forum for these leaders in the legal community to share their expertise on these issues.  The FCPA workshop led by Ms. Bennett, Ms. Cooper and Ms. Gomez focused on the practical and legal implications of an FCPA hypothetical fact pattern involving a non-US government contract bid, the crucial decisions that General Counsels and Compliance Officers need to make when confronted with such situations, and how to analyze and mitigate the risk of criminal and civil corporate liability under the FCPA.  Washington DC, September 22, 2016. 

Speaker, “Raising the Bar on Ethics Programs: New Developments,” Defense Industry Initiative on Business Ethics and Conduct annual Best Practices Forum 2011, Washington, DC, June 23, 2011

Speaker, “Hot Topics in Ethics and Compliance,” Defense Industry Initiative Webinar, December 08, 2010

Panelist, "Doing Business in Bad Neighborhoods: Tips and Challenges for Staying on the Right Side of the FCPA," Litigation Department Spotlight Live Seminar Series Event CLE Seminar, Chicago, IL, September 29, 2010

Speaker, "Bridge-the-Gap for Newly Admitted Attorneys 2010," Practising Law Institute, New York, NY, August 12, 2010

Speaker, "U.S. Legal Methods: Introduction to U.S. Law," The Institute of U.S. Law, Washington, DC, August 02, 2010

Panelist, "Doing Business in Bad Neighborhoods: Tips and Challenges for Staying on the Right Side of the FCPA," Litigation Department Spotlight Live Seminar Series Event CLE Seminar, Washington, DC, April 28, 2010

Moderator, “Defense Costs and Government Investigations: Making the Most of Your Company’s Insurance Coverage,” DC Bar, The Corporate Counsel Committee of the Corporation Finance and Securities Section and The Corporate Governance Committee of the Corporation Finance and Securities Section, Washington, DC, November 05, 2009

Panelist, "Around the World in 80 Indictments: Anti-Bribery Enforcement at Home and Abroad," ABA Section of International Law Spring Meeting, Washington, DC, April 14, 2009

Speaker, "No Cash Required: The Foreign Corrupt Practices Act and Corporate Risk,"  Ethisphere Webcast, September 29, 2008

Speaker, "Practical Guide to the Foreign Corrupt Practices Act," DC Bar, Washington, DC, May 05, 2008 Moderator, "FCPA Enforcement Under the Obama Administration? A Look Ahead…” American Bar Association Anti-Corruption Committee, Washington, DC, January 30, 2009