María González Calvet

Regulatory Inquiries

• Secured for Avianca Holdings, S.A., the publicly traded company behind Colombia’s flagship airline, a full declination and closure of the SEC’s and DOJ’s investigations into potential FCPA violations in connection with the provision of free airline tickets and other items of value to foreign government officials around the world.
• Go-to anti-corruption and investigations counsel to a global pharmaceutical and medical device manufacturer, assisting the client with numerous matters and both government-facing and internal investigations in multiple jurisdictions (including Argentina, Brazil, Chile, Ecuador, Italy, Mexico, and Portugal). The investigations largely concern allegations of corruption and involve regulators around the world.
• Assisted a global medical device and life sciences company with an internal investigation regarding whistleblower allegations of corruption and revenue recognition issues in Malaysia, India, and the Philippines, and successfully represented the client in its response to an SEC subpoena inquiring about similar issues in the same jurisdictions.
• Conducted an investigation for a global medical device and life sciences company following a Customs and Border Patrol (CBP) seizure of two of the company's U.S.-Mexico cross-border shipments found to have been contaminated with contraband. Conducted several interviews with key company personnel based in Mexico while coordinating with U.S. authorities and directing a third-party security consulting firm, operating across languages and jurisdictions.
• Assisted a global animal health company with conducting an internal investigation relating to potential violations of U.S. sanctions targeting Iran committed by its recently acquired portfolio company, submitting a voluntary disclosure to DOJ relating to potential criminal violations of sanctions (while our co-counsel handled the OFAC submission), and updating trade compliance checklist and export control policies.

Internal Investigations

• Global counsel to a personal holding company, conducting and overseeing a widespread and intensive investigation in multiple jurisdictions (including Portugal, France, the U.S., Israel, Luxembourg, Morocco, and the Dominican Republic), stemming from a high-profile arrest of the client’s co-founder on allegations of orchestrating a complex ring of fraud, money laundering, and tax evasion through company suppliers.
• Represented a Colombian software company in connection with an internal investigation into whistleblower allegations of improper payments related to the company's government contracts in Colombia and Chile.
• Conducted an internal investigation for an airline based in the Dominican Republic, a portfolio company of a major private investment firm, into whistleblower allegations that company employees made improper payments to local aviation inspectors in connection with the airline's launch.
• Conducted an internal investigation into allegations of improper workplace conduct for a multinational animal health technology and services company with operations in Spain.
• Following allegations of insensitive comments and possibly racially charged behavior, investigated and made recommendations regarding a company’s culture with respect to diversity, equity and inclusion.  
• Conducted an internal investigation for a global ceramics manufacturer into allegations of fraud and bribery in Vietnam, after irregularities were identified during a company audit by external auditors. Our investigation identified irregularities in additional jurisdictions, including India, Indonesia, Italy, Morocco, and Spain.
• Conducted an internal investigation into potential FCPA and other corruption risks arising from business dealings between a U.S.-based oil and gas company and a former Peruvian consultant who also held national public office in Peru at various points in time. The review included extensive, multilingual investigative steps, including document review covering a 20-year history, interviews, and engagement of experts to conduct forensic accounting analysis and public records review. Based on these findings, made remediation recommendations that sought to strengthen the client's practices and policies in several areas.
• Conducted a highly publicized internal investigation for a Chilean salmon farmer, portfolio company of one of the world's leading multi-asset alternative investment firms, following accusations that it had been reporting false mortality figures and had caused environmental damage.
• Retained by a multinational pharmaceutical company to investigate numerous allegations involving the company's vaccine study site in Latin America, including quality and dosing concerns, FCPA issues including possible retention of a government official, improper advance payments to offshore accounts, and counterfeit and fraud allegations.
• Represented a global life sciences company in relation to a cross-border investigation into bidding practices at government-operated health care institutions in Brazil.
• Retained by a global client to conduct an internal investigation into two of its Latin American affiliates that provided services to a Brazilian conglomerate that works in the fields of engineering, construction, and petrochemicals, which pleaded guilty in the U.S. to conspiracy to violate anti-bribery provisions of the FCPA by paying nearly a $1 billion in bribes to secure projects in 12 countries (including Brazil, Colombia, and Peru).
• Assisted an American biotechnology company with internal investigation into potential liability under the FCPA in connection with its distributor's alleged importation of narcotics into Argentina.
• Conducted an internal investigation for a global leader in medical technology, services, and solutions into allegations that a former Brazilian distributor made improper payments to health care providers.
• Representing an Ivy League university in an internal investigation into allegations of violations of federal laws and accreditation standards associated with non-human primate (“NHP”) animal research conducted at the university.

Compliance Counseling

• Assisted a global transportation networking company with a risk assessment and compliance program uplift for its operations in Latin America (in particular, Mexico, Chile, and Colombia).
• Conducted a compliance policy uplift for a leading global hygiene and health company, including a review and analysis of the company’s existing operations and risk across its operations in nearly 10 countries in Latin America and creation of tailored policies to address key areas of risk.
• Helped draft a global anti-corruption policy for a multinational retailer and provide training on a regular basis to the company’s Asia-based employees and vendors.
• Developed anti-corruption policies and procedures for an Argentinian real estate development company and conducted trainings of key personnel on relevant legal principles in Argentina and the U.S.
• Advised a global leader in medical technology, services, and solutions on the legal risk with respect to compliance with the FCPA in selling disposables and providing technical support to a Mexican distributor for capital equipment that the distributor purchased from the company.
• Assisted a hotel in Argentina, a portfolio company of an investment management client, with the restructuring of its anti-corruption compliance program.
• Conducted a proactive compliance review for a U.S.-based biopharmaceutical company of communications and other documents of employees in various jurisdictions in Europe, Asia, and Latin America, to identify the scope of interactions between company’s personnel and third parties and potential bribery and corruption concerns raised by such interactions.
• Advised a global animal health company in connection with a proactive compliance review in select markets (Brazil, China, and Italy) to test the effectiveness of the global compliance program, understand the local compliance culture, identify key risk areas, and determine timely risk mitigation strategies.

Individuals

• Representing a Brazilian executive who is cooperating with authorities in connection with enforcement proceedings in the U.S. (DOJ and SEC) and Brazil (Ministerio Publico Federal and Comissão de Valores Mobiliários) relating to the client’s alleged involvement in the paying of bribes to Brazilian government officials in exchange for loans issued by public financial institutions and potentially favorable legislation.
• Represented an individual employee of a multinational aerospace company in connection with cross-border enforcement actions by U.S., UK, and Spanish authorities against the employer regarding corruption, fraud, export control violations, and other related offenses over a 10-year period. Key issues included the alleged bribery of high-ranking government officials in several jurisdictions through third-party intermediaries in order to secure direct sales to government agencies.
• Represented a Venezuelan national in connection with a criminal investigation by the U.S. Attorney’s Office for the Southern District of Florida alleging that the client participated in a multijurisdictional scheme involving bribes, kickbacks, money laundering, and corruption in connection with the awarding and payment of contracts by Venezuela’s state-owned oil company, Petróleos de Venezuela SA (“PDVSA”), and its subsidiaries.
• Representing U.S. executives who, by way of trust, inherited oversight of an oil and shipping company that services the Caribbean.The individuals sought assistance in conducting an internal investigation related to the company’s alleged payment of bribes in exchange for favorable land grants and potential liability in connection with the arrest of a foreign political figure.
• Representing an executive of a Europe-based oil field equipment supplier in a DOJ investigation into potential FCPA violations in Mexico and other countries in Latin America.

Transactional Counseling

• Routinely assist clients across industries (asset management, health care/life sciences, manufacturing, private equity, retail, technology, etc.) with pre- and post-acquisition due diligence on potential investments in jurisdictions around the world.
• Served as anti-bribery and anti-corruption counsel to a U.S.-based dialysis services company in connection with the potential expansion of its operations into Latin America and Europe through acquisition of clinics, including in Brazil, Colombia, Ecuador, Guatemala, and Spain.
• Retained as international risk counsel to advise a U.S.-based multinational cold storage logistics company on anti-corruption, anti-money laundering, sanctions, and export controls risks in connection with a series of acquisitions of cold storage and logistics and transportation companies throughout Latin America.
• Advised a U.S.-based pharmaceutical company in negotiations with a global pharmaceutical company with a significant presence in China to enter into a co-promotion agreement with respect to one of the client’s drug products in China.