Joy Dowdle is a partner in the Litigation Department of Paul Hastings and is based in the firm’s Houston office. She represents corporations, audit and special committees, and individual officers and directors in internal investigations, as well as investigations by the Department of Justice (DOJ), Securities and Exchange Commission (SEC), and other regulatory agencies. Additionally, Ms. Dowdle represents clients in complex commercial and appellate litigation at the federal and state levels, including shareholder derivative and class-action lawsuits.
Ms. Dowdle has particular experience with international anti-bribery and anti-corruption (ABAC) law, including the Foreign Corrupt Practices Act (FCPA). She has been involved in advising corporations of all sizes and across industries in the design, enhancement, and implementation of their compliance programs (including policies and procedures, and internal controls); designing and providing comprehensive compliance training to management, employees, and third parties; advising on and conducting transactional anti-corruption due diligence and integration; and conducting investigations and corporate monitorships in Europe, Asia, Africa, and the Americas.
Representative Matters
Compliance, Investigations, and Monitorships
Advising a global, ex U.S.-based medical device company in the design and implementation of its ABAC compliance program and related financial controls and representing the company in its ongoing FCPA investigation by the DOJ
Advising a bio-pharmaceutical company on the enhancement of its global ABAC compliance program, including leading a review of the Company’s ABAC-related financial controls and resulting enhancements, conducting proactive reviews in markets across Asia, Europe, and Latin America, and assisting the Company in ongoing resolution negotiations of an FCPA matter before the DOJ and SEC
Advising a Fortune 100, multinational pharmaceutical company in the continued enhancement of its global ABAC compliance program, including conducting proactive reviews and advising on government-facing strategy and core program components including monitoring, investigations, and remediation
Conducted a global assessment of the ABAC compliance program and related financial controls of a Fortune 15 telecommunications, media, and entertainment company and advising the company (including senior management across operating companies and functions) on resulting program and control enhancements
Representing a multi-national pharmaceutical company in the anti-bribery and anti-corruption due diligence and integration efforts associated with a multi-billion dollar transaction
Served as company counsel facilitating an independent compliance monitorship arising from a top-10, global FCPA resolution with the Securities and Exchange Commission and Department of Justice (monitorship concluded without extension)
Designed and implemented an anti-corruption compliance program for a U.S.-based global exploration and development company
Conducted a global risk assessment and designed the global ABAC compliance program for a medical device company
Designed and implemented an anti-corruption compliance program for a consortium formed to build and operate a multi-billion-dollar oil and gas pipeline in Latin America
Participated in the corporate monitorship and successful close out of the deferred prosecution agreement of a Fortune 100, multi-national pharmaceutical company relating to alleged FCPA violations
Designed a compliance program and related internal controls for an oil and gas drilling and platform construction company
Conducted a Section 10A investigation on behalf of a multi-national chemical and refining company; resulted in favorable resolution with the auditor
Represented an up-stream oil and gas company in an FCPA investigation by the DOJ and SEC
Conducted an internal FCPA investigation on behalf of the special committee of the board of directors of an up-stream oil and gas company
Conducted an internal investigation on behalf of an up-stream oil and gas company relating to an oilfield death
Represented the chief financial officer of an office services and equipment company in a stock options backdating investigation by the SEC; resulted in favorable settlement
Represented the chief executive officer of a retail company in a Regulation Fair Disclosure investigation by the SEC; resulted in favorable pre-suit settlement
Represented the general counsel of a broker-dealer in an administrative proceeding by the SEC alleging failure to supervise; resulted in dismissal of all claims by the Commission
Participated in the corporate monitorship of a Fortune 50, multi-national corporation arising from resolution of FCPA violations
Civil Litigations
Represented an international offshore and onshore drilling and oil field services company in state and federal shareholder derivative actions related to DOJ and SEC investigations of alleged FCPA violations; resulted in favorable dismissals affirmed by the Fifth Circuit
Represented an international offshore drilling company in consolidated state and federal shareholder derivative actions related to resolution of DOJ and SEC investigations of alleged FCPA violations; resulted in favorable dismissals
Represented a pharmaceutical company and several of its directors and senior officers in shareholder derivative and class actions arising from DOJ and SEC investigations of alleged Medicaid fraud; resulted in favorable pre-trial settlement
Represented an internet service corporation in state and federal consumer class actions brought by subscribers; resulted in favorable dismissals
Represented a mutual fund company in a shareholder class action alleging misrepresentations in fund prospectus; resulted in a favorable dismissal
Other Distinctions
Recognized as a Texas Rising Star, 2013-2018
Listed in Texas Monthly’s selection of Top Attorneys—Texas’ Outstanding Young Lawyers, 2013–2018
Publications
Moderator, “An Interview with the Securities & Exchange Commission,” ACI’s 14th Annual Houston Forum on the Foreign Corrupt Practices Act, January 2020
Moderator, “Interacting with HCPs: Big Picture, Strategic Insights for Ethical Business Conduct, Anti-Corruption and Healthcare Compliance,” ACI’s 13th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, June 2019
Author together with Gary F. Giampetruzzi, Jessica R. Montes & Aisling Murray, Not A U.S.-Fits-All-Proposition: Four Key Considerations When Building the Compliance Framework to Go Global with Patient Support (Parts I and II), April 2019
Panelist, “More Insights into the Monitorship Process Behind the Curtain,” ACI’s 13th Annual Houston Forum on the Foreign Corrupt Practices Act, January 2019
Panelist, “Assessing the Value of ISO 37001 for Your Business – Whether, When and How to Seek and Maintain Certification,” ACI’s 12th Annual Houston Forum on the Foreign Corrupt Practices Act, January 2018
Presenter, “A Journey to the Dark Side of International Business – Leveraging Front Line Experience to Protect Your Organization and Embed Compliance and Ethics,” Society of Corporate Compliance and Ethics, Regional Compliance & Ethics Conference, Dallas, Texas, November 2017
Faculty, “The Foreign Corrupt Practice Act (and World-Wide Anti-Corruption Enforcement),” Seton Hall Law School, U.S. Healthcare Compliance Certification Program, June 2017
Panelist, “A Practical Debate on the Value of ISO 37001 and Other Compliance Certifications: Weighing the Pros and Cons in the Life Sciences Context,” ACI’s 11th Annual Forum on FCPA & Anti-Corruption for the Life Sciences Industry, June 2017
Panelist, “Sponsorship and Congresses: 5 Big Mistakes to Avoid,” ACI’s 11th Annual Forum on FCPA & Anti-Corruption for the Life Sciences Industry, June 2017
Presenter, “DOJ Compliance Program Evaluation Guidance: What is it and What does it mean?,” North Texas Ethics & Compliance Council, May 2017
Author together with Samuel W. Cooper, Christie A. Mathis & Betsey A. Boutelle, Going, Going, Gone: First Law of the Trump Administration Repeals Regulations Implementing Section 1504 Reporting Requirements for Payments to Governments by Oil, Gas, and Mining Companies, February 2017
Panelist, “The Transformative Impact of the SEC’s Whistleblower Program: How and Why Companies Need to Brace Themselves for an Increased Number of Reports and Awards to Protect Their Investors,” ACI’s 11th Annual Houston Forum on the Foreign Corrupt Practices Act, January 2017
Author with Gary F. Giampetruzzi & Katherine K. Solomon, Teva Pharmaceuticals Announces a Reserve of $520M in View of What Stands to Be the Fourth Largest FCPA Resolution to Date, November 2016
Panelist, “4th Oil and Gas Anti-Corruption Compliance Exchange,” Houston, Texas, October 2016
Author with Gary F. Giampetruzzi & Katherine K. Solomon, They Keep Coming: The SEC Enters a $5.5M Settlement with AstraZeneca PLC Resolving FCPA Allegations, September 2016
Author with Samuel W. Cooper & Spencer D. Bruck, Take Two—The SEC Adopts Section 1504 Reporting Requirements for Payments to Governments by Oil, Gas, and Mining Companies, July 2016
Faculty, “ACI’s Third Party Due Diligence and Monitoring Seminar,”
Chicago, IL, June, 2016
Author with Gary F. Giampetruzzi & Emmanuel Gastard, Seal the Deal: Four Steps to Effective FCPA Acquisition Due Diligence & Integration, May 2016
Author with Gary F. Giampetruzzi & Jena A. Sold, It’s Back—True to the Promise of Continued Scrutiny of Life Sciences, the SEC Enters a $25M FCPA Resolution with Novartis, April 2016
Author with Gary F. Giampetruzzi & Christopher F. Allen, Your Joint Venture In Fact Can Be Your Problem: Bristol Meyers Squibb Pays $14M to Resolve FCPA Allegations, October 2015
Author with Samuel W. Cooper, Proactive Thinking About International White Collar Investigations: How to Mitigate Risks and Manage Key Issues, International White Collar Enforcement, 2015 Edition
Author with Gary F. Giampetruzzi & Lucy B. Jennings, Inside Out: The SEC Awards $1 Million Plus to Yet Another Compliance Professional Turned Whistleblower, May 2015
Author with Gary F. Giampetruzzi & Jennifer A. Ebling, Not Finished With You Yet—The U.S. Government Extends its Deferred Prosecution Agreement with Biomet, Inc. Again Underscoring the FCPA Risk in Life Science, March 2015
Author with Gary F. Giampetruzzi & Lucy B. Jennings, SEC Sends a $30 Million-Plus Warning to Companies: Beware of Foreign Whistleblower, September 2014
Panelist, “Dodd-Frank sections 1502 (Conflict Minerals) & 1504 (Government Payment Reporting): Where things stand and What oilfield services companies are doing to prepare,” Institute for Energy Law, Oilfield Services Practice Committee Meeting, October 2013
Author with Samuel W. Cooper & Christie A. Mathis, Preparing for Shareholder Lawsuits When Dealing with Foreign Corrupt Practices Act Investigations, August 2013
Author with Samuel W. Cooper, Federal Court Vacates the SECs Section 1504 Reporting Requirements for Payments to Government by Oil, Gas, and Mining Companies, July 2013
Panelist, “Corporate Boards: Perspectives on Risk and Compliance Issues,” Ernst & Young Risk & Compliance Seminar, May 2013
Author, Long-Anticipated Guidance on the Foreign Corrupt Practices Act Released by the Department of Justice and Securities and Exchange Commission, November 2012
Panelist, “Managing Risk in A Global Economy,” Women’s Global Leadership Conference in Energy & Technology, October 2012
Author, Superman and the Selective Waiver Doctrine: The Potential Impact of Waiving Privilege in Government Investigations in Light of Parallel Litigation, July 2012
Author, SEC Approves Final Dodd-Frank Whistleblower Rules, May 2011
Prior Experience
Prior to joining Paul Hastings, Ms. Dowdle served as a law clerk to the Honorable E. Grady Jolly of the United States Court of Appeals for the Fifth Circuit, and practiced law in Houston, Washington, D.C., and London.