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Michael X. Marinelli has wide-ranging experience advising clients on compliance with the U.S. laws and regulations that apply to international operations and transactions. He focuses his practice on the Foreign Corrupt Practices Act (FCPA), as well as U.S. export control regulations, including the EAR, the ITAR, and the economic sanctions regimes enforced by the Office of Foreign Assets Control (OFAC).

Michael counsels clients in multiple industries, including energy, telecommunications, consumer electronics, software and life sciences, on complying with the broad array of statutes and regulatory regimes that apply to cross-border transactions. His practice includes assisting clients in the design, development and implementation of FCPA and export control compliance programs. As a member of the U.S. Technical Advisory Group, Michael participated in drafting and negotiating the ISO Anti-Bribery Management System Standard, ISO 37001. Michael also provides advice on individual transactions and relationships and evaluating compliance issues in the context of mergers and acquisitions.

Michael also has experience in FCPA and export enforcement matters, including conducting internal investigations, preparing and managing voluntary disclosures, and defending companies subject to criminal and civil investigations of possible violations.

Concentrations

  • Anti-Corruption and FCPA compliance
  • Export control and sanctions compliance
  • Internal investigations and voluntary disclosures

Capabilities

Experience

  • Global lead for design and implementation of an anticorruption compliance program for a Fortune 50 company with operations in Africa, Asia, Europe and the Americas
  • Global lead for design and implementation of an anti-corruption compliance program for a Fortune 500 company that acquired operations in the Caribbean and Latin America
  • Lead for project integrating newly acquired entity in India into parent company’s global anti-corruption compliance program
  • Designed and helped implement export control compliance program for U.S. computer hardware manufacturer
  • Designed and helped implement export control strategies for a Japanese consumer electronics company
  • Conducted anti-corruption risk assessments in multiple countries in Asia, Africa, the Caribbean and Latin America
  • Conducted global anti-corruption program assessments for clients operating in Asia, Africa, Europe and Americas
  • Advised major retailer on audit scope, methodology and reporting of findings
  • Advised client on scope, methodology and reporting of financial controls and procedural compliance monitoring
  • Advised clients on remediation of audit and monitoring findings
  • Conducted remote FCPA investigation involving employees and third parties in Malaysia and the U.K. for a construction equipment company
  • Conducted FCPA and export controls investigation in China for a U.S. computer manufacturer
  • Conducted FCPA investigation involving multiple countries for a U.S. manufacturer
  • Designed anti-corruption and export controls compliance training programs for management, board members, employees and third parties
  • Conducted over 100 in-person and remote training sessions

Credentials

Education
  • J.D., The Catholic University of America, Columbus School of Law
    • Editor-in-Chief, Catholic University Law Review
  • A.B., Brown University
Admissions
  • District of Columbia
  • U.S. Court of Appeals for the Federal Circuit
  • U.S. Court of International Trade
Admitted in the District of Columbia. Not admitted in Texas.