Stephanie Busalacchi focuses her practice on civil and criminal government enforcement matters and internal investigations for a wide range of companies and individuals, primarily in the healthcare, private equity and financial industries. Stephanie has conducted investigations into alleged anti-corruption violations under the FCPA and UK Bribery Act in several countries in Europe, Asia, Africa, and the Middle East, as well as investigations involving sanctions, trade compliance and other regulatory regimes. Stephanie assists a variety of clients with conducting risk-based pre-acquisition deal diligence on cross-border transactions and also helps companies to assess their own compliance programs and implement compliance enhancements. Stephanie spent three years on rotation with the firm’s London office and is now based out of the firm’s New York office.
Stephanie maintains a diverse pro bono practice with a focus on civil liberties. As part of the Partners in Prosecution Program, Stephanie also recently served as an Assistant District Attorney in Kings County, where she prosecuted a number of felony cases, including obtaining a conviction following a six-week jury trial.
- Regularly conducts pre-acquisition anti-corruption, anti-money laundering, and sanctions due diligence for large private equity firms and other clients in high-risk jurisdictions, including assisting with post-acquisition implementation of enhanced compliance controls.
- Drafts compliance policies for U.S., European and multinational companies addressing compliance with global anti-corruption and sanctions laws and conducts trainings for clients on the same.
- Conducts internal compliance investigations for clients in a number of sectors, including global healthcare, financial services, and manufacturing.
- Conducted an internal investigation into allegations of bribery and corruption in China on behalf of a multi-national pharmaceutical company.
- Advised a private equity firm on a global anti-corruption risk assessment.
- Advised a U.S. based international medical device company in an industry-wide FCPA investigation involving countries across Europe, Asia, and South America.
- Represented an investment management firm in investigations by the SEC.
- Represented a large medical device company in cross-border investigations into alleged violations of the Foreign Corrupt Practices Act and the UK Bribery Act in Europe, Asia and South America.
- Represented a healthcare company in a government inquiry into compliance with clinical trial registration and results reporting requirements.
- Represented an individual in a DOJ enforcement action related to EPA and consumer protection violations.
Pro Bono Practice
- Represented inmates in New York City jails in a class action against the City of New York, including leading the e-discovery portion of the litigation, drafting motions and memoranda, and taking depositions of key witnesses.
- Successfully obtained asylum in the U.S. for an individual fleeing persecution in his home country based on his sexual orientation.
- Co-author, “Piling On? Examining the Reality of Multi-Jurisdictional FCPA Resolutions,” The Anti-Corruption Report (July 11, 2018)