“[Audrey Harris] considers the big picture and understands what US authorities expect.”Chambers USA 2021
Audrey Harris is co-chair of Mayer Brown’s Global Anti-Corruption & FCPA practice and a former chief compliance officer (CCO) for global resources company BHP. Audrey’s career is dedicated to advising, counseling and defending companies, executives, boards and foundations in high-stakes investigations, governances, merger and acquisition, compliance and enforcement matters.
Audrey previously served as BHP’s first CCO, leading the global ethics and compliance function with a mandate including anti-corruption, trade sanctions, export controls, competition, ethics and investigations, state and commercial secrets and market conduct compliance, with a team of professionals and attorneys across four continents. Her team was accountable for safeguarding integrity by preventing, mitigating and investigating compliance risks and setting ethical standards. Her role also involved work with NGOs, international governing bodies and enforcement agencies as part of the promotion of global anti-corruption, transparency and integrity.
A veteran Foreign Corruption Practices Act (FCPA) and white collar practitioner, prior to becoming a CCO, Audrey was a partner at Mayer Brown with more than a decade of experience handling multi-year, multinational investigations, with a comprehensive investigations, counseling and defense capability.
Audrey regularly appears before enforcement authorities and has extensive experience in designing, executing and presenting internal investigations before multinational corporations, the US Department of Justice (DOJ), Securities & Exchange Commission (SEC), Department of Treasury Office of Foreign Assets Control (OFAC), Department of Defense and Multilateral Development Banks (MBDs). Her experience runs the gamut of white collar representations, including false claims act, healthcare fraud, management of earnings, money laundering defense and even anti-terrorism matters. Before joining Mayer Brown, Audrey was a partner at another leading global law firm.
Audrey has been repeatedly recognized in national and international publications. Chambers USA 2021 ranked Audrey as one of the nation’s leading practitioners for FCPA, with clients noting that “she is an amazing attorney – very smart and extremely hard-working” and possesses “a wealth of experience.” She was named to The National Law Journal’s list of “Criminal Law Trailblazers” (2020) and to Global Investigations Review’s inaugural “Women in Investigations” list (2015).
- Represented one of the largest engineering companies in the world, with an annual revenue of more than $27 billion and operations in more than 100 countries, in connection with an investigation and deferred prosecution agreement with DOJ and the SEC. This was one of the first cases to result in a self-monitoring provision, avoiding an expensive external monitor.
- Successful representations and resolutions for a variety of multinational corporations including:
- A global fuel specialties and additive manufacturer, in a matter involving DOJ and U.K. Serious Fraud Office (SFO);
- A worldwide designer and manufacturer of medical devices -- successfully resolving an industry-wide FCPA investigation; and
- A top global management consulting, and technology services provider in a FCPA internal investigation and DOJ/SEC voluntary disclosures -- which were resolved without enforcement action.
- Representing a leading integrated resort company in a DOJ/SEC FCPA investigation concerning activities in China.
- Designed, executed and presented numerous FCPA internal investigations for multinational corporations, including defense before enforcement authorities such as the DOJ, SEC, the World Bank and MBDs, as well as coordinating defense of parallel international enforcement authority actions, and related civil litigation.
- Led FCPA due diligence for a $900M+ divestiture and executed an expedited multinational review resulting in a successful on-time closing.
- Worked with multinational clients to create & execute FCPA compliance programs, policies & procedures, compliance gap reviews, testing/controls analysis, internal audit & investigation capabilities and proactive anti-bribery reviews.
- Designed & successfully implemented FCPA compliance, due diligence, and merger and acquisition strategies for global companies including in the engineering, reinsurance and financial fields.
- Counseled numerous private equity & investment firms on FCPA risk mitigation in emerging markets.
- Successfully represented individuals in multiple FCPA investigations, including defense industry executives.
Government Contracting/False Claims/False Statements Defense
- Defended CFO of major advertising company in SDNY trial against false claims/false statements allegations related to a government contract.
- Advised multinational corporation in Congressional inquiry into government program.
- Counseled and designed internal investigation for international defense contractor in response to government subpoena and inquiry.
- Conducted internal investigation and advised large defense contractor with regard to civil and criminal enforcement liability arising from billing and payment practices.
Healthcare Related Representations.
- Advised two large health care companies on civil and criminal enforcement liability arising from claims adjudication, billing, and payment practices.
- Advised medical device manufacturer in successful defense against adulteration, misbranding and misstatements allegations.
- Advised and designed internal investigation for medical device manufacturer regarding payments, business relationships, and entertainment of medical professionals.
- Counseled pharmaceutical company regarding merger due diligence related to business relationships and entertainment of medical professionals.
- Presenter at legal and compliance training program for in-house counsel of international medical device and services company.
Additional Securities & Exchange Commission Matters
- Represented CFO of major U.S. corporation in SEC investigation and enforcement action, bringing matter to successful resolution.
Georgetown University Law Center, JD, magna cum laude
Order of the Coif; Michael Feldman Advocacy Award; Vincent G. Panati Memorial Award Criminal Justice Clinic; Administrative Editor, The Tax Lawyer
Miami University, MA, Political Science (International Relations)
Presenter and Panelist at Middle Eastern Studies Association Conference, 1997
University of Central Florida, BA, summa cum laude, Political Science
Honors in the Major; Pi Sigma Alpha
- District of Columbia
- US Court of Appeals for the Fourth Circuit
- US District Court for the Eastern District of Virginia
- US District Court for the District of Columbia
- Board Member, Coalition for Integrity
- Appointed to Law360 Compliance and White Collar Editorial Advisory Boards, 2020 and 2021
- Board Member, That Others May Live Foundation
- Mayer Brown
- Firm Wide Women’s Leadership Forum
- DC Office Recruiting Committee
- DC Office Committee on Associates and Counsel
- DC Office Women’s Forum
- Former Associate Editor, Business Crimes Bulletin
- Ranked by Chambers USA for Nationwide – FCPA, 2021
- Named to The National Law Journal’s inaugural list of “Criminal Law Trailblazers,” 2020
- Named to Global Investigations Review’s inaugural “Women in Investigations” list, 2015