Joshua Drew and a Career in FCPA Enforcement and Compliance

I recently had the opportunity to visit with Joshua Drew, formerly a lawyer at the Department of Justice (DOJ) at Main Justice in Washington and also an Assistant US Attorney at the US Attorney’s Office for the District of New Jersey. We visited for an episode of the FCPA Compliance Report podcast.

Drew has recently joined the litigation group at Miller & Chevalier. With his extensive background in the fraud section of the DOJ and in-house roles at companies dealing with False Claims Act cases and FCPA resolutions, Joshua brings a wealth of knowledge and experience to his new position. His expertise will contribute to Miller & Chevalier’s strategic growth.

Drew moved from governmental service to HP, where he was Vice President and Associate General Counsel, Ethics & Anti-Corruption. At the time, HP was in the middle of a major FCPA investigation in the early 2010s. One of Joshua’s notable achievements was his role at HP, managing responses to DOJ and SEC investigations related to potential FCPA violations. During his time at HP, he played a crucial role in improving the internal investigation process, which resulted in a more efficient and practical approach. This experience highlights Joshua’s ability to navigate complex compliance issues and find practical solutions.

From HP, he moved to the company formerly known as VimpelCom, now VEON. He began as Associate General Counsel-Investigations and became the Group’s Chief Ethics & Compliance Officer. VimpelCom was going through an FCPA enforcement action and resolution at the time. He helped guide the company through a rigorous Deferred Prosecution Agreement (DPA) and monitorship. VEON was one of several high-profile FCPA enforcement actions involving telecom companies in Uzbekistan who paid huge bribes, totaling over several billion, to the daughter of the then President of the country, a woman named Gulnara Karimova.

Several factors influenced Joshua’s decision to join Miller & Chevalier. Firstly, he was impressed by the firm’s strong team of lawyers, many of whom he had interacted with during his time in-house at VimpelCom. The firm’s reputation for excellence and expertise in practice areas such as FCPA work, false claims act cases, general litigation, and white-collar defense also aligned well with Joshua’s experience. Additionally, Miller & Chevalier’s strategic focus and subject matter expertise in the issues that arise in a DC practice were appealing to Joshua.

Drew also discussed the new Safe Harbor Policy for Mergers and Acquisitions under the FCPA, which was announced in 2023. This policy encourages companies to disclose potential misconduct and cooperate with DOJ investigations, providing strong incentives for companies to get to the bottom of possible misconduct. Drew emphasized the importance of companies conducting thorough investigations, understanding the facts, and making decisions based on all available information in the company’s best interest. He acknowledged that these decisions can be challenging and require careful judgment.

The move to Miller & Chevalier allows Joshua to leverage his skills and experience to contribute to the firm’s strategic growth. His background in dealing with DOJ enforcement actions and his expertise with monitorships will be valuable assets in building on the firm’s existing work in these areas. Joshua’s role at Miller & Chevalier is focused on litigation, and he aims to bring strength to strength by complementing the skills and experience of the firm’s lawyers.

Joshua’s joining Miller & Chevalier brings the firm a unique blend of DOJ and in-house experience. His expertise in FCPA compliance and internal investigations will be instrumental in helping clients navigate complex compliance issues and mitigate risks. With his strategic approach and commitment to excellence, Joshua is well-positioned to make a significant impact at Miller & Chevalier.

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