Representation in Internal and Government Investigations  

A multinational manufacturer discovered that one of its contractors submitted visa applications with false statements in support of U.S. immigration benefits. The manufacturer relied heavily on this contractor to supply highly specialized foreign talent to advance its innovation and artificial intelligence projects. As a result, the manufacturer found itself at the crossroads of corporate liability for criminal and regulatory violations and needed to understand its obligations, as well as the contractor’s obligations.  

• The company engaged our Government Strategies and Compliance group to conduct an internal investigation and advise the manufacturer on its decision whether to report any findings to the United States Government. 
• Our team also assisted the company in navigating the delicate relationship with its contractor, including facilitating conversations with the contractor’s counsel to gather key facts and documents, and drafting communications with the contractor regarding the manufacturer’s ultimate decision to terminate the relationship.  

• Our team gathered and reviewed relevant documents and interviewed both the contractor’s employees and its Chief Executive Officer in the United States, as well as the company’s employees who were involved in the contractual relationship.  

Our team’s investigation found the company’s employees had little, if any, knowledge about the contractor’s misrepresentation. The company terminated its relationship with the contractor while limiting interruptions to its immigration program and wider business operations.