We have handled matters involving potential violations of: the Foreign Corrupt Practices Act; best price and other Medicaid regulations; anti-kickback rules applicable to the pharmaceutical industry; numerous potential accounting problems, including most recently a significant number of options backdating issues; auditor and director independence issues; and many instances of potential executive misconduct.
Cravath has represented numerous clients in federal and state governmental investigations, including in response to inquires from the United States Congress, the Securities and Exchange Commission, the Department of Justice, the Federal Trade Commission, various state attorneys general, the New York Stock Exchange and the National Association of Securities Dealers. In recent years, Cravath has represented Bristol-Myers Squibb, the audit committee of General Electric, IBM, King Pharmaceuticals, Lucent Technologies, Time Warner and Vivendi Universal, among others, in connection with publicly disclosed SEC enforcement proceedings. We have conducted, or provided advice with respect to, investigations all around the world, in virtually every industry, and covering possible violations of a wide range of regulations and laws.
As a general matter, most of our work in connection with government and internal investigations is not publicly disclosed.