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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, a Chambers USA Recognized Practitioner in the Foreign Corrupt Practices Act (FCPA), 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, 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.

She serves as Independent Compliance Monitor for SNC-Lavalin Group, Inc. on behalf of the International Bank for Reconstruction and Development and International Development Association (World Bank) with a mandate to review and evaluate the company's global anti-corruption compliance program.  Ms. Bennett also regularly advises corporate clients on their anti-corruption compliance programs and on specific policies, procedures and compliance questions and has designed and led large-scale corporate compliance reviews and audits. Ms. Bennett, Joseph Covington, and Carlos Grover served as U.S. counsel to the Special Committee of the Board of Directors of Petróleo Brasileiro S.A. (Petrobras), a committee formed to provide independent oversight of the company’s internal investigation and remediation in connection with Operação Lava Jato.

Ms. Bennett entered private practice after serving as a federal criminal defense lawyer in the District of Columbia Federal Public Defenders’ office.

Ms. Bennett is Co-Chair of the Public International and Criminal Law Subcommittee for the District of Columbia Bar, International Law Community, Co-Chair of the Chapter Subcommittee of the Women’s White Collar Defense Association, and a Member of the WWCDA Chapter Launches Subcommittee. She is also a member of the White Collar Committee of the National Association of Criminal Defense Lawyers (NACDL) and of the Advisory Board of The Champion, a monthly journal published by NACDL.

Chambers USA 2020 ranks Ms. Bennett in the area of USA - Nationwide - Foreign Corrupt Practices Act. Chambers USA describes her as an "experienced investigations lawyer and team player" who "presents concerns in an organized manner that makes clients feel comfortable." She maintains a well-regarded FCPA investigations practice that covers a large range of jurisdictions, aided by her fluency in Spanish.

Chambers USA 2020, in which Ms. Bennett is ranked for FCPA, describes her as an "experienced investigations lawyer and team player" who "presents concerns in an organized manner that makes clients feel comfortable,"  with a well-regarded FCPA investigations practice that covers a large range of jurisdictions, aided by her fluency in Spanish.

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

Co-Author, Iris E. Bennett and Cormac T. Connor, A Defense Counsel's Guide to New DOJ Manual, Law360 Expert Analysis, October 2018.

Co-Author, Iris E. Bennett, Cormac T. Connor, and Jonathan D. Shaffer, DOJ Focuses FCA Priorities on Small Business Contracts, Law360 Expert Analysis, August 2018.

Co-Author, Iris E. Bennett, Sean Hartigan, et al,, FCPA Disgorgement: Putting SEC To Its Burden Of Proof, Law360 Expert Analysis, August 4, 2017.

Co-Author, Iris E. Bennett, Sean Hartigan, et al., The 9th Circ.'s Expansive Reading Of Escobar In Gilead, Law360 Expert Analysis, July 26, 2017.

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

Co-Author, Foreign Corrupt Practices Act: Central District of California Rejects Argument that State-Owned Corporations Can Never Be 'Instrumentalities' of Foreign Governments, ABA Business Law Section, Business Law Today, June 30, 2011.

Co-Author, Iris E. Bennett, Sean Hartigan, et al.,  Sharing is Caring in DOJ’s View of FCPA Cooperation, Law360 Expert Analysis, December 7, 2010.

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

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

Speaking Engagements

“Preserving Your Client's Privileges and Confidences During Internal Investigations,” District of Columbia Bar Association (June 3, 2020)

"Inside a Monitorship from Start to Finish: Important Lessons on Compliance and Remediation,” American Conference Institute (ACI) International Conference on the Foreign Corrupt Practice Act, National Harbor, MD, December 5, 2019. 

“Comparative Developments in Criminal Justice Systems in Argentina, Brazil, Mexico and the U.S.,” District of Columbia Bar Association (September 12, 2019).

Moderator, Joe Chontos and Melanie S. Cibik, “Procurement Fraud: Turning the Table on the Government,” NACDL's 9th Annual West Coast White Collar Crime Conference, Santa Monica, CA, June 2019.

Moderator, “In-House Compliance Roundtable,” ACI 6th Annual Summit on Anti-Corruption Mexico City, Mexico, March 28, 2019.

Moderator, Natalie Lockwood, Thuy Tran and Shannon O. Young, “Anti-Corruption Workshop: Hot Topics and Compliance Best Practices,” Compliance Ethics Institute, Society of Corporate Compliance and Ethics, Las Vegas, Nevada, October 21, 2018.

Moderator, Jennifer Mattis, Brenda Morris and Catherine Kane Ronis, “Ethical Issues in Internal Investigations and in Responding to Government Investigations,” Women, Influence & Power in Law Conference, Washington, DC, October 5, 2018.

Moderator, Patricia Byrne, Rochelle Cooper and Nancy McCready Higgins, “FCPA Enforcement Trends and Compliance Best Practices,” Women, Influence & Power in Law Conference, Washington, DC, October 11, 2017.

Co-Panelist, John S. Pachter, Iris E. Bennett and Jim Winner, “Government Investigations and Enforcement – Cooperation, Defense, and Settlement Strategies,” Association of Corporate Counsel, National Capital Region, Government Contractors Forum, July 12, 2017.

Co-Panelist, Iris E. Bennett, Rochelle Cooper and Maria E. Gomez, "FCPA Triage Workshop,” Women, Influence & Power in Law Conference, Washington, DC, September 22, 2016.

Speaker, “Raising the Bar on Ethics Programs: New Developments,” Defense Industry Initiative on Business Ethics and Conduct 2011 Annual Best Practices Forum, 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 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, 2008.

Languages

Spanish

Portuguese

Awards and Recognition

Chambers USA: America’s Leading Lawyers for Business USA-Nationwide: Foreign Corrupt Practices Act, Band 4 (2020)

Professional Memberships

District of Columbia Bar, International Law Community, Public International and Criminal Law Subcommittee, Co-Chair

Women’s White Collar Defense Association, Chapter Subcommittee, Co-Chair

WWCDA Chapter Launches Subcommittee, Member

White Collar Committee of the National Association of Criminal Defense Lawyers (NACDL), Member, NACDL The Champion Journal, Advisory Board Member