In-House Counsel

GC Credited with Breaking Bribery Ring at Company

Jay Dalton, a now-retired general counsel of an international oil and gas pipeline company, is getting credit for not only helping find employees who were bribing foreign government officials, but stopping them from continuing the scheme.

Corporate Counsel examined Dalton’s involvement after the late January sentencing of two former executives of a subsidiary of Panama-based Willbros Group Inc., where Dalton was general counsel.

The two men pleaded guilty to conspiracy to violate the Foreign Corrupt Practices Act in a scheme to win a $400 million Nigerian pipeline contract.

Corporate Counsel noted that Dalton played a key role in investigating the scheme and putting a stop to “consultant” payments that were being used for bribes.

William Johnson, a partner in Fried Frank’s government investigations and regulatory counseling practice, told Corporate Counsel that Dalton’s efforts can serve as an example for in-house lawyers who need help convincing boards and executives of the value of improving and expanding compliance programs.

“That fact that the general counsel got some credit for stopping this scheme is something companies should want,” Johnson said. “It’s definitely something that makes the company look good and the general counsel look good.”

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