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 Nationwide 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 have served as 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 the “Lava Jato” matter. Click here for a link to the press release announcing the formation of the Special Committee.
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.
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; and 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.
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
State of California, 2000
District of Columbia, 2005
Commonwealth of Virginia, 2016
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
A Defense Counsel's Guide to New DOJ Manual, Law360 (October 2018)
DOJ Focuses FCA Priorities on Small Business Contracts, Law360 (August 2018)
Expert Analysis, FCPA Disgorgement: Putting SEC To Its Burden Of Proof, Law360 (August 4, 2017)
Expert Analysis, The 9th Circ.'s Expansive Reading Of Escobar In Gilead, Law360 (July 26, 2017)
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
Moderator: Procurement Fraud,Turning the Table on the Government, NACDL's 9th Annual West Coast White Collar Crime Conference, Santa Monica, California (June 2019), with Joe Chontos, Aeroject Rocketdyne Holdings, Inc., and Melanie S. Cibik, Senior VP, General Counsel and Secretary, Teledyne Technologies Incorporated
Moderator: In-House Compliance Roundtable, ACI's 6th Summit on Anti-Corruption Mexico City, Mexico (March 28, 2019)
Moderator: Anti-Corruption Workshop Hot Topics and Compliance Best Practices, Compliance Ethics Institute, Society of Corporate Compliance and Ethics, Las Vegas, Nevada, October 21, 2018, with Natalie Lockwood, General Motors Company, Thuy Tran, Regional Integrity Officer-USA, SNC-Lavalin, Shannon O. Young, US Employment and Ethics Counsel, WSP USA Inc.
Moderator: Ethical Issues in Internal Investigations and in Responding to Government Investigations, Women, Influence & Power in Law conference, Washington, D.C., October 5, 2018, with co-panelists Jennifer Mattis, Corporate Counsel, Investigations, Northrop Grumman Corporation, Brenda Morris, Deputy General Counsel, Booz Allen Hamilton, Inc., and Catherine Kane Ronis, Vice President & Associate General Counsel, Litigation and Investigations, BAE Systems, Inc.
Moderator: FCPA Enforcement Trends and Compliance Best Practices, Women,Influence & Power in Law conference, Washington, D.C., October 11, 2017, with co-panelists Patricia Byrne, Vice President & Associate General Counsel, International Compliance, BAE Systems, Inc., Rochelle (“Shelly”) Cooper, Corporate Counsel, Northrup Grumman Corporation, and Nancy McCready Higgins, Vice President & Chief Ethics & Compliance Officer, Bechtel Group, Inc.
Panelist: Government Investigations and Enforcement – Cooperation, Defense, and Settlement Strategies, Association of Corporate Counsel, National Capital Region, Government Contractors Forum, July 12, 2017 12-2pm, with co-panelists John S. Pachter and Iris E. Bennett to lead a panel discussion with Jim Winner, Chief Legal Officer and General Counsel of a new company being formed by MHVC Acquisition Corporation, formerly Harris Corporation’s Government Services business.
Panelist: FCPA Triage Workshop, Women, Influence & Power in Law conference, Washington, D.C., September 22, 2016, 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.
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, 2008
Chambers USA: America’s Leading Lawyers for Business USA-Nationwide: Foreign Corrupt Practices Act, Recognized Practitioner (2018)