Business Opportunities and Risks in Venezuela: Best Practices for Navigating a Compliance Minefield

Mr. Ellis founded and leads the firms globally recognized Latin America practice. He guides clients on cross-border internal investigations and corporate compliance strategies to address bribery and corruption/U.S. Foreign Corrupt Practice Act (FCPA) allegations, anti-terrorism/Foreign Terrorist Organizations (FTOs), fraud, economic sanctions, AML, business and human rights (BHR)/forced labor, multilateral development bank (MDB) sanctions, workplace misconduct (including sexual harassment, discrimination, and retaliation), conflicts of interest, and other sensitive ethics and compliance matters. Legal and compliance departments, boards of directors, audit committees, and private equity firms regularly look to Mr. Ellis to lead independent investigations, perform compliance due diligence in M&A, and build corporate compliance strategies to align with the expectations of the U.S DOJ, the SEC, and other global regulators. He previously worked as a Litigation Specialist and Investigator at the World Bank and the Inter-American Development Bank (IDB) and currently advises companies on development bank investigations and sanctions proceedings. 

Mr. Griffin's practice focuses on national security and international trade, with an emphasis on economic sanctions, export controls, information and communications technology and services (ICTS), the Committee on Foreign Investment in the United States (CFIUS), customs, and tariffs. He rejoined the firm after serving in senior policy roles at both the Department of the Treasury's Office of Foreign Assets Control (OFAC) and the Department of Commerce's Bureau of Industry and Security (BIS). At OFAC and BIS, Mr. Griffin was deeply involved in high-stakes, pressing sanctions and export control issues, with a focus on Russia, Iran, China, Venezuela, Afghanistan, counterterrorism, and working with U.S. companies to detect diversion networks used by U.S. adversaries to obtain high-priority U.S. technology. He brings this deep government experience to his representation and advice for clients at the firm, including in representation before U.S. government agencies, day-to-day compliance issues, anticipation of future policy priorities and government actions, internal investigations, risk assessments, and gap analyses. 

Mr. Tillen is Vice Chair of the firm’s International Department. His practice focuses on matters involving the FCPA, money laundering, business and human rights, and other areas of international corporate compliance. He has significant experience with every facet of an FCPA enforcement matter, from inception to completion, including developing work plans for internal investigations, conducting internal investigations, developing remediation strategies, and negotiating resolutions. He has also conducted anti-corruption due diligence reviews and compliance audits.