In the wake of a series of serious corporate scandals both domestic and international, public legal compliance expectations are at an all-time high, and it is not uncommon for a single scandal to destroy a large company. Under these circumstances, when a company discovers a potential compliance issue, it is expected to promptly clarify the relevant facts and take appropriate measures in response to its findings.

We have extensive experience in internal investigations of compliance issues not only in Japan but also overseas. We have a large number of attorneys and staff specialized in these investigations. We also work with experts in various fields, such as outside accounting firms and global risk consultants, to maintain strict information management and provide investigative reports, analyses of legal risks and advice on corrective measures and measures to prevent the recurrence of violations.

When dealing with overseas compliance issues, we work with compliance and investigation experts at local Baker & McKenzie offices who are familiar with local languages and business practices to assist clients with internal investigations and corrective measures. Experts with extensive experience in reaching plea agreements with foreign law enforcement agencies, including the US DOJ and SEC, will also assist in negotiations with these agencies. In addition, we provide media support based on the results of internal investigations when necessary.

Representative Experience

  • Assisted in many internal investigations with respect to improper accounting practices by Japanese listed companies and Japanese subsidiaries of NYSE-listed companies.
  • Assisted a Japanese company listed on the NYSE in relation to an internal US FCPA investigation into alleged bribery in a southeast Asian country.
  • Supported many Japanese listed companies in internal investigations into alleged bribery in Asian countries.
  • Assisted a Japanese company in responding to global media in relation to a compliance scandal involving its Singapore subsidiary in cooperation with an external PR agent.
  • Involved in an internal investigation as a member of the third-party investigation committee for a Japanese railway consulting firm in relation to bribery cases in Vietnam, Indonesia and Uzbekistan.
  • Assisted a Japanese IT engineering company in an internal investigation into improper practices in relation to a public procurement project in a southeast Asian country financed by an international development and financial institution and in settlement negotiations with said institution.
  • Assisted several foreign healthcare companies with internal investigations into alleged breaches of the Pharmaceutical Affairs Law and negotiations with the relevant authorities.
  • Represented a foreign healthcare company in conducting an internal audit and investigation of the client’s Japanese subsidiary regarding fraud and embezzlement of over JPY1.4 billion by an employee of the Japanese subsidiary.